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Respiratory Protection Index

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Introduction

Many substances may be harmful if inhaled.  These may be dusts such as wood dusts or chemical powders, mists such as water-based chemical sprays, fumes from operations such as welding, or vapors such as evaporating cleaning solvents.  When it is not possible to remove these hazards with engineering controls (for example, substituting non-harmful products or installing exhaust ventilation) it may be necessary to use respiratory protection.

It is the intent of this policy that, as necessary, the University of Rochester shall:

• evaluate tasks and workplaces to determine if respiratory protection is needed
• evaluate employees’ medical status before issuing respirators (and if necessary, to accommodate those employees who can not wear respiratory protection for medical reasons)
• provide training on the proper selection, use, care, and limitations of respirators
• provide properly fitted respirators to any employees who may need them
• perform any other tasks necessary to comply with OSHA’s 29 CFR 1910.134, Respiratory Protection, and 29 CFR 1910.139, Respiratory Protection for M. tuberculosis

No employee may be fitted for, issued, or required to use a respirator of any sort without complying fully with this document.

Responsibilities

Environmental Health and Safety (EH&S)

It is the responsibility of Environmental Health and Safety to:

• maintain the University of Rochester’s written Respiratory Protection Plan
• evaluate tasks and workplaces where respiratory protection is required
• provide fit testing and training in cooperation with the Occupational and Environmental Medicine Program and University Health Service’s Occupational Health Unit
• periodically review and update written respiratory protection policies and procedures
• provide compliance assistance to the University community
• eriodically evaluate departments’ compliance with this document

Occupational and Environmental Medicine Program and University Health Service’s Occupational Health Unit

It is the responsibility of the Occupational and Environmental Medicine Program and University Health Service’s Occupational Health Unit to:

• provide medical clearances to University employees required to use respiratory protection
• provide employees and supervisors written results of the medical clearance
• recommend ways for the University to accommodate employees who are not medically capable of wearing respiratory protective equipment
• provide fit testing and training in cooperation with Environmental Health and Safety

University Administration, Directors, Managers, and Supervisors

It is the responsibility of University Administration, Directors, Managers, and Supervisors to:

• ensure that the employees who report to them are in compliance with this document
• establish site-specific procedures for the use and care of respirators
• establish record keeping guidelines for records related to this program (i.e., training records, medical clearance memos, and site-specific procedures)
• designate a person responsible for managing their departments compliance with the Respiratory Protection program
• provide their employees with training for site-specific hazards, policies, and precautions

Respiratory Protection Users

It is the responsibility of respiratory protection users to:

• wear respiratory protection for tasks or areas that require it
• follow site-specific procedures
• attend training classes
• keep medical clearance appointments
• inspect respiratory protective equipment prior to each use
• store their respirator in a clean and sanitary manner, away from potential sources of contamination
• clean and disinfect their respirator regularly
• perform a negative and positive pressure fit check before each use
• report damaged or malfunctioning equipment immediately

Respirator Selection

Proper respiratory protection selection is made only after a determination has been made as to the real and/or potential exposure of employees to harmful concentrations of contaminants in the workplace atmosphere. This evaluation will be performed prior to the start of any routine or non-routine tasks requiring respirators.  The following items will be considered in the selection of respirators:

• effectiveness of the device against the substance of concern
• estimated maximum concentration of the substance in the work area
• general environment (open shop or confined space, etc.)
• known limitations of the respiratory protective device
• comfort, fit, and worker acceptance
• the task to be performed
• other contaminants in the environment
• potential for oxygen deficiency
• a verification of the respirator’s NIOSH certification for its intended use

Some common examples of work, which may require the use of respirators, include, but are not limited to:

• asbestos abatement activities
• abrasive blasting
• cutting or melting lead or stripping lead-based paints from surfaces
• welding or burning
• painting, especially with epoxy or organic solvent coatings
• using solvents, thinners, or degreasers
• any work which generates large amounts of dust
• working in a permit-required confined space
• using formaldehyde to decontaminate a space
• administering certain drugs, such as pentamidine
• work with bioaerosols such as M. tuberculosis

Supervisors shall contact EH&S (x5-3241) well in advance of non-routine work, which may expose workers to hazardous substances or oxygen deficient atmospheres.

No respirator may be used for any purpose if it has not been NIOSH certified for that purpose.

Assigned Protection Factors (APFs) for Respirators

APFs are numbers that indicate the level of workplace respiratory protection that a respirator or class of respirators is expected to provide to employees when used as part of an effective respirator protection program. The APF table below is provided as a guide in the selection of air purifying, powered air-purifying, supplied air (or airline respirator), and self contained breathing apparatus (SCBA) respirators.

APFs must be used to select the appropriate type of respirator based upon the exposure limit of a contaminant and the level of the contaminant in the workplace. Respirators are selected by comparing the exposure level found in the workplace and the maximum concentration of the contaminant in which a particular type of respirator can be used (the Maximum Use Concentration, or MUC). The MUC is determined by multiplying the respirator’s APF by the contaminant’s exposure limit. If the workplace level of the contaminant is expected to exceed the respirator’s MUC a respirator with a higher APF must be chosen.

Example:

Question: Employees use a respirator with an Assigned Protection Factor (APF) of 10. What would the maximum use concentration be when the hazardous substance has a permissible exposure limit of 50 ug/m³?

Answer: 500 ug/m³ The MUC is determined by multiplying the respirator’s APF by the contaminants exposure limit. For example, when the hazardous substance is lead (with a PEL of 50 ug/m³), and the respirator used by employees has an APF of 10, then the calculated MUC is 500 ug/m³ or 0.5 mg/m³ (i.e., 50 ug/m³ x 10). If the level of the contaminant is expected to exceed the MUC, a respirator with a higher APF must be chosen.

Notes:

¹ Employers may select respirators assigned for use in higher workplace concentrations of a hazardous substance for use at lower concentrations of that substance, or when required respirator use is independent of concentration.

²The assigned protection factors in the table are only effective when the employer implements a continuing, effective respirator            program as required by this section (29 CFR 1910.134), including training, fit testing, maintenance, and use requirements.

³ This APF category includes filtering face pieces, and half masks with elastomeric face pieces.

⁴ The employer must have evidence provided by the respirator manufacturer that testing of these respirators demonstrates performance at a level of protection of 1,000 or greater to receive an APF of 1,000. This level of performance can best be demonstrated by performing a WPF or SWPF study or equivalent testing. Absent such testing, all other PAPRs and SARs with helmets/hoods are to be treated as loose-fitting facepiece respirators, and receive an APF of 25.

⁵ These APFs do not apply to respirators used solely for escape. For escape respirators used in association with specific substances covered by 29 CFR 1910 subpart Z, employers must refer to the appropriate substance-specific standards in that subpart. Escape respirators for other IDLH atmospheres are specified by 29 CFR 1910.134 (d)(2)(ii).

Conditions which are Immediately Dangerous to Life and Health

Some circumstances may arise where it is not possible to accurately identify or estimate potential exposures.  If this should occur, the task or area shall be considered immediately dangerous to life and health (IDLH).  Oxygen deficient atmospheres shall also be considered IDLH.  IDLH conditions require the use of either a full-face pressure demand self contained breathing apparatus with at least 30 minutes of air, or a full-face pressure demand supplied-air respirator with auxiliary self-contained air supply.  These types of respirators are described below.

Types of Respirators

Air-Purifying Respirator

These respirators remove air contaminants by filtering, absorbing, adsorbing, or chemical reaction with the contaminants as they pass through the respirator canister or cartridge. This type of respirator is to be used only where adequate oxygen is available and the atmosphere is not oxygen enriched (19.5 to 23.5 percent by volume). Air-purifying respirators can be classified as follows:

• Particulate removing respirators, which filter out dusts, fibers, fumes and mists. These respirators may be single-use disposable respirators or respirators with replaceable filters.
  NOTE:  Surgical masks do not provide protection against air contaminants. They are never to be used in place of an air-purifying respirator. They are for medical use only, in cases where the patient must be protected from contamination from employees or visitors.
• Gas- and vapor-removing respirators, which remove specific individual contaminants or a combination of contaminants by absorption, adsorption or by chemical reaction. Gas masks and chemical-cartridge respirators are examples of gas- and vapor-removing respirators.
• Combination particulate/gas- and vapor-removing respirators, which combine the respirator characteristics of both kinds of air-purifying respirators.
• Powered air-purifying respirators, which operate on the same principle as air-purifying respirators, but rely on a blower unit to move air through filters and deliver it to the user.

Supplied-Air Respirators

These respirators provide breathing air independent of the environment. Such respirators are to be used when the contaminant has insufficient odor, taste or irritating warning properties, or when the contaminant is of such high concentration or toxicity that an air-purifying respirator is inadequate. Supplied- air respirators, also called airline respirators, are classified as follows:

• Demand respirators, which supply air to the user on demand (inhalation), which creates a negative pressure within the facepiece. Leakage into the facepiece may occur if there is a poor seal between the respirator and the user's face.
• Pressure-Demand respirators maintain a continuous positive pressure within the facepiece, thus preventing leakage into the facepiece.
• Continuous Flow respirators maintain a continuous flow of air through the facepiece and prevent leakage into the facepiece.
• Self-contained Breathing Apparatus (SCBA) respirators allow the user complete independence from a fixed source of air and offer the greatest degree of protection, but are also the most complex respirator type. Training and practice in its use and maintenance is essential. This type of device shall be used in emergency situations, situations which are immediately dangerous to life or health, when there is an oxygen deficient or enriched atmosphere, or when hazards cannot be adequately characterized only.

Identification of Respirator Cartridges and Gas Mask Canisters

Respirator cartridges and canisters are designed to protect against individual hazards or a combinations of potentially hazardous atmospheric contaminants, and are specifically labeled and color-coded to indicate the type and nature of protection they provide.

The NIOSH approval label on the respirator will also specify the maximum concentration of contaminant(s) for which the cartridge or canister is approved. For example, a label may read:

"DO NOT WEAR IN ATMOSPHERES IMMEDIATELY DANGEROUS TO LIFE. MUST BE USED IN AREAS CONTAINING AT LEAST 20 PERCENT OXYGEN. DO NOT WEAR IN ATMOSPHERES CONTAINING MORE THAN ONE-TENTH PERCENT ORGANIC VAPORS BY VOLUME. REFER TO COMPLETE LABEL ON RESPIRATOR OR CARTRIDGE CONTAINER FOR ASSEMBLY, MAINTENANCE, AND USE."

No respirator or respirator cartridge may be used in a way that is not consistent with its labeling, manufacturers recommendations, instructions on material safety data sheets (without advice from a health and safety professional from EH&S), standard operating procedures, EH&S guidelines, or this document.

Service Life of Air-Purifying Respirator Canisters and Cartridges

The canisters or cartridges of air-purifying respirators are intended to be used until filter resistance precludes further use, or the chemical sorbent is expended as signified by a specific warning property, e.g., odor, taste, end of service life indicator (ELSI), etc.  New canisters, cartridges or filters shall always be provided when a respirator is reissued. When in doubt about the previous use of the respirator, obtain a replacement canister or cartridge.

Warning Signs of Respirator Failure

Particulate Air-Purifying

When breathing difficulty is encountered with a filter respirator (due to partial clogging with increased resistance), the filter(s) must be replaced. Disposable filter respirators must be discarded.

Gas or Vapor Air-Purifying

If, when using a gas or vapor respirator (chemical cartridge or canister), any of the warning properties (e.g., odor, taste, eye irritation, or respiratory irritation) occur, promptly leave the area and check the following:

• proper face seal
• damaged or missing respirator parts
• saturated or inappropriate cartridge or canister
• end of service life indicator (ELSI)

If no discrepancies are observed, replace the cartridge or canister. If any of the warning properties appear again, the concentration of the contaminants may have exceeded the cartridge or canister design specification. When this occurs an airline respirator or SCBA is required.

Supplied Air Respirator

When using an airline respirator, leave the area immediately when the compressor failure alarm is activated or if an air pressure drop is sensed. When using an SCBA leave the area as soon as the air pressure alarm is activated.

Respirator Use

Respiratory protection is authorized and issued for the following employees:

• workers in areas known to have contaminant levels requiring the use of respiratory protection or in which contaminant levels requiring the use of respiratory protection may be created without warning (e.g., emergency purposes such as hazardous material spill responses)
• workers performing operations documented to be health hazardous and those unavoidably required to be in the immediate vicinity where similar levels of contaminants are generated
• workers in suspect areas or performing operations suspected of being health hazardous but for which adequate sampling data has not been obtained

Employees may not wear respiratory protective equipment if he or she has any condition (i.e., facial hair, clothing, or hairstyle, etc.), which may interfere with the proper fit and operation of the respirator.  If an employee requires corrective lenses, these lenses must be worn during operations involving respiratory protective equipment, and must be worn in such a way as to not interfere with the respirator’s seal or operation.

Those employees who would like to voluntarily wear respiratory protective devices in the absence of recognized exposures or hazards may do so.  However, these employees must follow the Voluntary Respirator Use section of this document.

Written site and or task specific standard operating procedures  (SOPs) are required before employees may use respiratory protective equipment.  It is the responsibility of the employee’s supervisor to develop these SOPs with the assistance of EH&S, to distribute them to his or her affected employees, and to take whatever steps are necessary to ensure that the SOPs are followed at all times.

Respirator Use for Biohazards

Respirators for use in areas where biohazards are used or stored must be selected based on a review of the laboratory procedures, protocols, biohazardous agents proposed for use, etc. The Institutional Biosafety Committee, in cooperation with EH&S, the supervisor, and the researcher, will conduct a risk assessment and determine the appropriate Biosafety Level for the laboratory and the corresponding level of personal protective equipment required. Employees who use respirators for protection from M. tuberculosis should refer to the section Respiratory Protection for M. tuberculosis, below.

Voluntary (Comfort) Respirator Use

Under some circumstances, employees may wish to use respiratory protection equipment for their own comfort or sense of well being, even when there is no recognized hazard or over exposure.  In these cases, not all of OSHA’s respiratory protection requirements apply (i.e., fit testing is not required). In order to voluntarily use respiratory protective equipment in this way, the following criteria must be met:

• there is no recognized hazard or potential for over exposure
• the respirator must be NIOSH certified
• the respirator must be cleaned, stored, and maintained as specified in Care of Respiratory Protective Equipment, below
• the respiratory protective equipment does not itself present a hazard to the user
• the employee is medically cleared to use a respirator (Exception: filtering facepieces (i.e., dust masks, “duck bill” respirators, etc.) do not require a medical clearance for voluntary use)
• the employee is given a copy of the appendix Information for Employees using Respirators When Not Required Under the Standard
• the employee and his/her supervisor must sign the release form contained in Appendix A, acknowledging that they have received a copy of Appendix A, Information for Employees using Respirators When Not Required Under the Standard Sec. 1910.134, Appendix D. The form must be kept on file in the department's respiratory protection records.

Employees who would like to voluntarily wear a respirator may purchase and wear their own respirator or may ask their department to supply one for them.

Care of Respiratory Protective Equipment

In order to be effective and to properly protect the user, respirators must be regularly inspected, cleaned, and maintained.  It is the responsibility of the respirator user to ensure that his or her respirator is inspected before each use, is kept in a clean and sanitary condition, is stored away from sources of contamination, is maintained properly, and that any problems with the equipment are reported immediately for repair or replacement. Disposable respirators should be discarded if they become soiled or contaminated, or at a minimum, at the end of each work shift.

Cleaning and Disinfecting

The Occupational Health and Safety Administration have set guidelines for the cleaning of respiratory protective equipment.  These are listed below.  Alternatively, respiratory protective equipment can be cleaned according to the manufacturers recommendations so long as the equipment is cleaned and disinfected in a way that does not damage it, and does not harm the user.

1. Remove filters, cartridges, or canisters. Disassemble facepieces by removing speaking diaphragms, demand and pressure-demand valve assemblies, hoses, or any components recommended by the manufacturer. Discard or repair any defective parts.
2. Wash components in warm (43 deg. C [110 deg. F] maximum) water with a mild detergent or with a cleaner recommended by the manufacturer. A stiff bristle (not wire) brush may be used to facilitate the removal of dirt.
3. Rinse components thoroughly in clean, warm (43 deg. C [110 deg. F] maximum), preferably running water. Drain.
4. When the cleaner used does not contain a disinfecting agent, respirator components should be immersed for two minutes in one of the following:
   1. Hypochlorite solution (50 ppm of chlorine) made by adding approximately one milliliter of laundry bleach to one liter of water at 43 deg. C (110 deg. F)
   2. Aqueous solution of iodine (50 ppm iodine) made by adding approximately 0.8 milliliters of tincture of iodine (6-8 grams ammonium and/or potassium iodide/100 cc of 45% alcohol) to one liter of water at 43 deg. C (110 deg. F)
   3. Other commercially available cleansers of equivalent disinfectant quality when used as directed, if their use is recommended or approved by the respirator manufacturer.
5. Rinse components thoroughly in clean, warm (43 deg. C [110 deg. F] maximum), preferably running water. Drain. The importance of thorough rinsing cannot be overemphasized. Detergents or disinfectants that dry on facepieces may result in dermatitis. In addition, some disinfectants may cause deterioration of rubber or corrosion of metal parts if not completely removed.
6. Components should be hand-dried with a clean lint-free cloth or air-dried.
7. Reassemble the facepiece, replacing filters, cartridges, and canisters where necessary.
8. Test the respirator to ensure that all components work properly.

Storage

Respiratory protection equipment must be stored in a way that protects them from damage, dust, contamination, sunlight, chemicals, excessive moisture, and extreme temperatures.  They must also be stored in such a way that it is unlikely that the facepiece or valves will be damaged or deformed.  Additionally, emergency respirators must be stored in an easily accessible way in the workplace, must be in containers clearly labeled as containing emergency respirators, and according to any manufacturers recommendations.  Self-contained breathing apparatus (SCBA) cylinders must be stored fully charged, and must be recharged whenever they fall below 90% full.

Inspection

The following checks are required as part of the respirator inspection procedure:

• respirator function
• tightness of connections
• condition of  the facepiece, head straps, valves, connecting tubes, and cartridges, canisters, or other filters
• pliability of any elastomeric parts
• signs of cracking, discoloration, or other symptoms of aging
• tank pressure (SCBAs)
• regulator and pressure alarm bell function (SCBAs)
• tank condition (SCBAs)

In addition, emergency respirators must be inspected by performing the checks above and certifying that they have been performed by tagging or labeling the respirator with the date of the inspection, the name and/or signature of the inspector, a serial number or other identifying means, the condition of the respirator, and any needed repairs or other maintenance.

When using respirators routinely, these inspections must be performed before each use and during each cleaning.  Emergency respirators shall be checked before being brought into the workplace, and periodically thereafter, and SCBAs must be checked at least monthly.  Inspection records must be kept until the time of the next inspection.

Repairs

Respirators found to be defective or in need of repairs must be removed from service immediately. When repairing a respirator or replacing cartridges, valves or other components, only approved parts shall be used to keep the NIOSH approval valid.  No attempts, under any circumstances, should be made to change, modify, or improve any respiratory protection device.  Only specially trained and qualified technicians shall make repairs to SCBA’s, pressure regulators, and other sensitive devices.

Filter Change Schedules

SCBAs are usually equipped with a warning of service life. It may be a pressure gauge or timer with audible alarm or a window indicator for canisters. The respirator user must understand the operation and limitations of each type of warning device.

Many new cartridge/canister air purifying respirators are equipped with an end‑of‑service‑life indicator (ESLI), a system that warns the respirator user of the approach of the end of adequate respiratory protection, for example, that the sorbent is approaching saturation or is no longer effective (US DOL OSHA, 1998). If there is no ESLI appropriate for conditions in the employer's workplace, the employer must 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 to prevent contaminant breakthrough (Jeffress, 1998). The employer shall describe in the respiratory protection 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.  Employees voluntarily wearing APRs regularly with organic vapor cartridges shall change the cartridges on their respirators if they detect breakthrough, i.e., odor or irritation.  However, the following chemicals have substance-specific standards under OSHA and cartridges must be changed accordingly:

• Acrylonitrile - ESLI or end of shift, whichever occurs first.
• Benzene - ESLI or beginning of shift, whichever occurs first.
• Butadiene - Every 1, 2, or 4 hours dependent on concentration and at beginning of shift.
• Formaldehyde - Every three hours or end of shift, whichever occurs first.
• Vinyl chloride - ESLI or end of shift in which they are first used, whichever occurs first.
• Methylene chloride - ESLI or end of shift in which they are first used, whichever occurs first.

Employees wearing APRs or PAPRs with P100 filters for protection against dust and other particulates shall change the cartridges on their respirators when they first begin to experience difficulty breathing (i.e., resistance) while wearing their masks.

Developing change schedules can be a complex task.  The following guidelines are provided to assist employers with determining change out schedules for canisters and cartridges:

• Availability of objective data: Determine if respirator manufacturers, industry organizations, trade associations, professional societies, chemical manufacturers, or academic institutions can provide objective data for the particular make and model of the respirator canisters/cartridges and if this data is sufficient to develop change out schedules.
• Use of inappropriate respirator cartridge/canister: Determine if APRs are appropriate for the conditions in the workplace.  Some chemicals break through canisters and cartridges so quickly that canisters and cartridges may not be appropriate for the workplace.  In this case, employers should consult with respirator manufacturers and material safety data sheets for instruction.
• Change schedule for mixtures: Chemical mixtures can present a difficult task when developing change schedules.  This is best determined by experimental methods, not predictive mathematical models.  Schedules should be calculated by assuming the mixture stream behaves as a pure system of the most rapidly migrating component or compound with the shortest breakthrough time, i.e., sum up the concentration of the components.  A margin of safety for the user should be included.
• Chemical contaminant migration: When organic materials with a boiling point below 65 degrees Centigrade are imbedded in a carbon filter, some may have a tendency to migrate through the sorbent material during periods of storage or when not in use.  This can rapidly increase breakthrough and could present an additional exposure to the user.  Whenever migration is possible, canisters and cartridges should be changed after every workshift.
• Emergency Response:  Chemical cartridges used for emergency response will be changed after each use.
• Voluntary Use:  Employees voluntarily wearing APRs regularly with organic vapor cartridges shall change the cartridges on their respirators as recommended by the manufacturer.

Quality of Supplied Air (from tanks or compressors)

Supplied air respirators provide high levels of protection, but only if the air source is free of contamination and other hazards.  OSHA has issued the following requirements for the quality of supplied air, along with requirements for air supplying equipment.  These requirements are:

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

For SCBAs:

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

Compressors used to supply breathing air to respirators shall be constructed, situated, and maintained so as 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 shall be maintained and replaced or refurbished periodically following the manufacturer's instructions.
• have a tag containing the most recent sorbent bed change date and the signature of the person authorized by the employer to perform the change. The tag shall be maintained at the compressor.
• for compressors that are not oil-lubricated, the employer shall ensure that carbon monoxide levels in the breathing air do not exceed 10 ppm.
• for oil-lubricated compressors, the employer shall 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 shall be monitored at intervals sufficient to prevent carbon monoxide in the breathing air from exceeding 10 ppm.
• the employer shall ensure that breathing air couplings are incompatible with outlets for nonrespirable worksite air or other gas systems. No asphyxiating substance shall be introduced into breathing airlines.
• the employer shall use breathing gas containers marked in accordance with the NIOSH respirator certification standard, 42 CFR part 84.

Medical Evaluation

Using a respirator can place an extra burden on an employee.  The respirator’s weight, breathing resistance, and tendency to trap heat can all contribute to an increased workload and increased fatigue.  In order to ensure that this potential for increased exertion does not place the employee at medical risk, the employee must receive a medical evaluation and a medical clearance prior to the use of respiratory protective equipment (except for disposable filtering facepieces as described in the voluntary respirator use section).  This medical evaluation and clearance shall be performed by a physician or other qualified, licensed health care professional under the guidance and supervision of University Health Service’s (UHS) Occupational Health Unit or Strong Memorial Hospital’s Occupational and Environmental Medicine Program (OEMP).  The evaluation must be performed during the employee’s normal working hours, or at a time and place convenient for the employee.

Task Information

The following information must be supplied in writing to UHS or OEMP by the employee’s supervisor, prior to the employee’s medical clearance:

• the type and weight of the respirator to be used by the employee;
• the duration and frequency of respirator use (including use for rescue and escape);
• the expected physical work effort;
• any additional information requested by UHS or OEMP;
• additional protective clothing and equipment to be worn; and
• temperature and humidity extremes that may be encountered.

Medical Evaluation Procedures and Questionnaire

OSHA requires that the medical evaluation consist of a medical questionnaire, and/or a physical examination, which provides the same information as the questionnaire, and any needed follow-up medical examinations.  OSHA’s mandatory medical clearance questionnaire is located in Appendix D of this document.  The medical evaluation shall also include any tests, procedures, or other information that the evaluating medical professional feels is appropriate.

Medical Determination

Upon completion of the medical evaluation, UHS or OEMP shall provide the employee, his or her supervisor, and EH&S with a statement of the employee’s ability or inability to wear a respirator, any limitations on respirator use due to medical or work conditions, and the need (if any) for follow-up medical evaluations.  Additionally, UHS and OEMP must provide a statement that the employee has been given a copy of the medical evaluation and medical determination results.

Additional Medical Evaluations

Additional medical evaluations shall be scheduled when:

• the employee reports signs or symptoms that are related to respirator use or the employee’s ability to use a respirator
• UHS, OEMP, EH&S, or the employee’s supervisor request a re-evaluation
• observation of the employee indicates a need for re-evaluation
• there are changes in the workplace or task that may significantly increase the employee’s exertion while wearing a respirator (i.e., physical work changes, temperature changes, added protective clothing, etc.)

Additional medical evaluations shall consist of whatever exams, tests, or other information that the medical professional feels is necessary to evaluate the employee.

Employees Who Can Not Be Medically Cleared

For those employees who cannot be medically cleared to wear negative pressure respirators, the University shall provide the employee with a suitable powered air-purifying respirator (if available, and if the employee can be medically cleared for its use).  The University may also accommodate the employee in other ways as recommended by UHS, OEMP, EH&S, the supervisor, and representatives of Employee Relations, Personnel, and/or other employment-related University departments.  Employee’s who perform tasks which require SCBAs, PAPRs, or other supplied air respirators and who cannot be medically cleared shall also be accommodated according to safety, medical, and legal procedures and requirements.

Fit Testing

In order to ensure that respiratory protective equipment provides a good fit, and therefore good protection without excessive leaks, employees must successfully complete a fit test.  Employees shall be fit tested with the same model, size, and style of respirator that they will use, and shall be fitted at least annually.  Employees shall also be fit tested whenever:

• a different size, style, or model of respirator is to be used
• whenever there are changes in the employees physical condition that could affect the respirator seal (such as an obvious change in weight, facial scarring, dental changes, or surgeries involving the face and head)
• whenever the employee reports a change in the fit of his or her respirator

Fit testing shall be performed using one of the following OSHA approved qualitative or quantitative fit test methods:

• Isoamyl Acetate (banana oil) vapor*
• Saccharin Solution Aerosol*
• Denatonium Benzoate (Bitrex ™) Solution Aerosol*
• Irritant Smoke (Stannic Chloride)*
• Generated Aerosol
• Ambient Aerosol Condensation Nuclei Counter (PortaCount ™)
• Controlled Negative Pressure

Those methods that are marked with an asterisk are qualitative methods.  These methods rely on the employee’s response to the challenge agent (taste, smell, cough, etc.) to determine an adequate fit.  Qualitative fit test methods shall not be used when a fit factor of 100 or greater is needed.

Quantitative fit test methods (i.e., generated aerosol, ambient aerosol condensation nuclei counter, and controlled negative pressure) must indicate a fit factor of at least 100 for half-face respirators, and at least 500 for full-face respirators to be considered successful.

Tight fitting supplied air respirators shall be fit tested by temporarily converting them to negative pressure respirators.

In addition to the formal fit tests, the employee shall perform a check of the respirator’s seal before each use.  The respirator user can check his or her seal by performing either a positive seal check or a negative seal check.  To perform a positive seal check, close off the exhalation valve and exhale gently into the facepiece. The face fit is considered satisfactory if a slight positive pressure can be built up inside the facepiece without any evidence of outward leakage of air at the seal. For most respirators this method of leak testing requires the wearer to first remove the exhalation valve cover before closing off the exhalation valve and then carefully replacing it after the test.  To perform a negative seal check, close off the inlet opening of the canister or cartridge(s) by covering with the palm of the hand(s) or by replacing the filter seal(s), inhale gently so that the facepiece collapses slightly, and hold the breath for ten seconds. The design of the inlet opening of some cartridges cannot be effectively covered with the palm of the hand. The test can be performed by covering the inlet opening of the cartridge with a thin latex or nitrile glove. If the face piece remains in its slightly collapsed condition and no inward leakage of air is detected, the tightness of the respirator is considered satisfactory.

If these tests cannot be performed successfully, the employee shall inspect the respirator and ensure that any needed repairs are made.  If the respirator still does not fit properly and there is no obvious respirator defect, the employee must be retested for a proper fit.

Training

In order to provide adequate protection, employees must be trained on the proper use and care of respiratory protective equipment.  This training shall be given annually and shall include the following points:

• 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 and 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; and
• the general requirements of this section.

The University shall ensure that employees can demonstrate their knowledge of these areas by use of a competency exam.  Employees who do not pass this exam shall be retrained, and may not use respiratory protective equipment or perform tasks that require it until they successfully complete the exam.

Employees shall be retrained at least annually, and whenever there are changes in the workplace or task that make previous training obsolete, it becomes apparent that the employee’s knowledge of respiratory protection is inadequate, and when any other situation arises that indicates a need for retraining.

Record Keeping

UHS, the OEMP and EH&S retain written information regarding medical evaluations, fit testing, and the University of Rochester Respiratory Protection Program.

Records of medical evaluations are retained and made available in accordance with 29 CFR 1910.1020.

An established record of the qualitative and quantitative fit tests is retained and includes:

1. The name or identification of the employee tested;
2. Type of fit test performed;
3. Specific make, model, style and size of respirator tested;
4. Date of test;
5. The pass/fail results for QLFTs or the fit factor and strip chart recording or other recording of the test results for QNFTs.

These records are retained for respirator users until the next fit test is administered.

A written copy of the University of Rochester’s Respirator Protection Program can be obtained from EH&S, UHS or OEMP.

Respiratory Protection for M. tuberculosis

As of July 1, 2004, the references to Respiratory Protection for M. tuberculosis 29CFR1910.139 shall be removed from the Infection Control Manual. The Infection Control Manual shall reference the OSHA Standard 29 CFR 1910.134 for protection against TB.

QUESTIONS? Contact EH&S at (585) 275-3241 or e-mail EH&S Questions.

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