John Dimos and Paul Satti Construction Safety Council
These illnesses are attributed to the chemicals we work with to the very building materials we mold into structures and roads. As a contractor, knowing the basics of an effective respiratory protection program will allow a better understanding of the seriousness of the hazard. Important: Respirators should be used for protection only when engineering controls have been shown to be infeasible for the control of the hazard or during the interim period when engineering controls are being installed. An effective respiratory protection program needs to be able to perform the following key functions:
(a) Need for Respiratory Protection Respirators are required to be worn by workers whenever the following three conditions arise:
If those three conditions do not exist, then the use of respirators is not required. If an employer allows voluntary use of respirators, then, they must do the following:
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. When using a respirator, do the following:
(b) Respirator SelectionThe type of respirator to use in any situation is determined by the Program Administrator. OSHA requires that an employer designate a Program Administrator to oversee employee respiratory protection and ensure compliance to the OSHA Regulations. Cartridge-type respirators or air supplying respirators can only reduce exposures to hazardous gases or vapors. Filtering facepiece respirators, filtered elastomeric facepiece respirators, or air supplying respirators can reduce exposures to hazardous dusts, fumes, mists and other particles. Each type of mask gives a different level of protection, measured by the amount of air leaking into the mask where it comes in contact with the face. A respirator can only reduce exposure never eliminate it. The Program Administrator must take into account the type of exposure, the level of exposure (amount) and other work and environmental factors to choose the most appropriate respirator to protect workers. Some features of the different types of respirators are as follows: Filtering Face Piece, Half-Face, Disposable, Negative Pressure, Air-Purifying Respirator Disadvantages: Least protection (although rated the same as elastomeric half-face), still has to be fit tested if used to reduce exposures above PEL, not allowed for use in atmospheres with less than 19.5% Oxygen.
Elastomeric Half-Face, Cartridge/Filter, Negative Pressure, Air-Purifying Respirator Disadvantages: Still hard to get a good fit with some people, requires regular cleaning and periodic disinfecting, requires maintenance and replacement of parts, not allowed for use in atmospheres with less than 19.5% Oxygen, may be difficult to use with other PPE (safety glasses, under welding hoods/helmets, with face shields). Elastomeric Full-Face, Cartridge/Filter, Negative Pressure, Air-Purifying Respirator
Disadvantages: Requires regular cleaning and periodic disinfecting, requires maintenance and replacement of parts, not allowed for use in atmospheres with less than 19.5% Oxygen, may be difficult to use with prescription eyewear, no glasses with side bars, contact lenses allowed). Powered Air-Purifying Respirator (PAPR)
Advantages: Provides a reduction of exposure by a factor of 50 (2 % leakage), built in safety eye protection (face piece meets or exceeds ANSI Z87.1), easier to fit, easier on heart and lungs.
Advantages: Provides a reduction of exposure by a factor 2,000 (0.05% leakage), built in safety eye protection (face piece meets or exceeds ANSI Z87.1), easier to fit, easier on heart and lungs, requires Compressed Gas Association (CGA) Grade D breathing air, can be used in Oxygen deficient atmospheres with appropriate escape measures provided (belt mounted escape air bottle).
(c) Medical Evaluation After determining which respirator is required, the Program Administrator needs to make sure that the employees are physically able to wear the respirators required. The medical evaluation is performed in one of two manners. First, a confidential questionnaire (Appendix C of the Respirator Standard, 29 CFR 1910.134) can be given during work hours or at a time and location convenient for the workers. It must be given in a language that the employee can read. OSHA has translated the questionnaire into Spanish. If the employee cannot read, they may bring someone from home to read the questions to the employee. The employer may not provide this person, or be present during the questioning. After completing the questionnaire, the employee puts it into an envelope and seals it. The employer can then send the sealed questionnaire to their designated Physician or Licensed Health Care Professional (PLHCP). Another method of medical evaluation is to send the employee to the PLHCP for a face-to-face evaluation where the PLHCP asks the same questions as those found on the questionnaire. The employer must provide a copy of their written respirator program to the PLHCP as well as the medical evaluation section of the Respirator Standard. After evaluating the employees, the PLHCP sends a letter back to the employer stating four things:
This is the Medical Record, which must be kept for the employee’s duration of employment plus thirty (30) years thereafter. At no time does the employer ever see the questionnaire. Note: 29 CFR 1926.33 contains the standard for medical records and their retention. (d) Fit Testing The next step is to fit test the employee with the selected respirator. There are four methods of fit testing qualitatively (pass/fail) and three methods quantitatively (measures actual fit). These are detailed in Appendix A of the Respiratory Protection Standard, 29 CFR 1910.134. OSHA allows qualitative testing for all respirators except full-face, negative pressure, air-purifying respirators.
Prior to the fit test, a fit check is performed to make sure a good seal is obtained. In addition, the employee should wear the mask for five minutes prior to fitting to ensure comfort. Fit checks are done both negatively and positively. To perform a negative pressure fit check; cover the inlets to the filters or cartridges, and inhale to cause the face piece to pull against the face. The employee then holds their breath. If the face piece relaxes, there is a substantial leak and either another mask is selected or the mask is adjusted.
After passing the fit check, the fit test can be performed. The qualitative fit test is done using a taste test (saccharin or Bitrex ), an odor test (banana oil/iso amyl acetate), or a reaction test to irritant smoke. The quantitative tests use machines to measure the actual leakage through the face seal of particles or the change in pressure due to air leakage. The three tests are corn oil mist particle counting, condensation nuclei counter (CNC) or PortaCount, and the Dynatech FitTester 3000, which measures pressure difference. They all need adapters to allow sampling inside the mask. Employees must be re-fitted at least annually. Additional fit testing may be required if the employee:
(e) Training In addition to the fit testing, employees require training on how to use, maintain, store, clean and disinfect their respirators (procedures for cleaning and disinfecting are found in Appendix B of the Respiratory Protection Standard, 29 CFR 1910.134). The wearer must be trained on the respirator’s limitations. This training must be performed prior to using the respirator in a work or rescue environment and must include annual refresher training and re-training when an employee demonstrates misuse. The training, as with the medical questionnaire, must be in a language that the employee understands. (f) Written Program Finally, after selection, medical clearance, fit testing and training, an employee is able to wear a respirator in the work area. The Program Administrator is required to have at the job site a written program that details specifically each aspect of respirator use at that site. This written program must be made available to employees or their representatives and OSHA compliance officers during inspections. |