Respiratory Protection Plan - Environmental Health & Safety

Community College of Rhode Island

Respiratory Protection Program

Introduction

This respirator program lays out standard operating procedures to ensure the protection of all employees from respiratory hazards through proper selection and use of respirators. Respirators are to be used only where engineering control of respirator hazard is not feasible while engineering controls are being installed, or in emergencies. This program is in accordance with the requirements of OSHA 29 CFR 1910.134.

Administrative Duties

At the Community College of Rhode Island the Respiratory Protection Program Administrators are Emanuel G. Terezakis, Chemical Safety Coordinator (tel 401-333-7140) and Kenneth McCabe, Physical Plant Director (tel. 401-825-2111). They are responsible for the program and have authority to make necessary decisions to ensure success of this program. Their authority includes purchasing equipment necessary to implement and operate the program. The Program Administrators will develop written detailed instructions covering each of the basic elements in this program, and is authorized to amend these instructions.

They are also qualified by appropriate training and experience to administer or oversee the Respiratory Protection Program and conduct the required evaluations of program effectiveness.

Copies of this respiratory Protection Program are distributed at the time of training. Any employee may review the Program. Copies are located in the College Learning Resource Centers, in the offices of the Physical Plant Directors of the Knight and Flanagan Campuses and in the offices of the Chemical Safety Coordinator and Physical Plant director. The Physical Plant Directors and the Chemical Safety Coordinator review this program periodically to ensure its effectiveness.

Respirator Selection

Respirators are selected on the basis of respiratory hazards to which the worker is exposed and workplace and user factors that affect respirator performance and reliability. All selections are made by the Program Administrator or one of the Physical Plant Directors.

The Program Administrator has developed detailed written standard operating procedures governing the selection of respirators using the following guidelines based on 29 CFR 1910.134(d).

SELECTION PROCEDURE CHECKLIST

Respirators are selected and provided based on respiratory hazard(s) to which a worker is exposed and workplace and user factors that affect respirator performance and reliability.
Only NIOSH-certified respirators are selected.
Respiratory hazard(s) in the workplace must be identified and evaluated, including a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant's chemical state and physical form.
An atmosphere is considered to be IDLH (immediately dangerous to life and health) if the employee exposure cannot be identified or reasonably estimated. No College employee is allowed to enter an IDLH area.
Respirators are selected from a sufficient number of respirator models and sizes so that the respirator is acceptable to, and correctly fits, the user.
All oxygen-deficient atmospheres are considered to be IDLH and may not be entered by any employee.
When selecting respirators for atmospheres that are not IDLH a respirator that is adequate to protect the health of the employee must be supplied to ensure compliance with all other OSHA statutory and regulatory requirements, under routine and reasonably foreseeable emergency situations.
Respirators are selected for the appropriate chemical state and physical form of the contaminant.
For protection against gases and vapors, an air-purifying respirator must be provided that: (1) is equipped with an end-of-service-life indicator (ESLI) certified by NIOSH for the contaminant; or (2) If there is no ESLI appropriate for conditions in the workplace, a change schedule for canisters and cartridges must be implemented that is based on objective information or data that will ensure that canisters and cartridges are changed before the end of the service life.
For protection against particulates, there must be provided 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 particulate by NIOSH under 42 CFR 84.

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 the Community College of Rhode Island, persons will not be assigned to 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 medical evaluation will be performed by Occupational Health + Rehabilitation located in Pawtucket, RI and Warwick, RI or by another agency or physician chosen by the College.

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. A medical questionnaire is administered so that the employee understands its content.

Before any initial examination or questionnaire is given, the College will 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 of the respirator to be used by the employee
Duration and frequency of respirator use
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 has the ability to use or not use a respirator, he/she sends the Community College of Rhode Island 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 or not 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 an employee's initial medical examination demonstrates the need for a follow-up medical examination. The 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, the College will not allow the employee to work in an environment where a respirator is needed.

Additional Medical Examinations:

The College 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 respirator program administrator 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

Fit Testing Procedures

Respirators must 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 the respirator program.

Qualitative fit testing will be administered by the PLHPC who carries out the medical evaluation. 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. If that user can detect the presence of the test agent through subjective means, such as odor, taste, or irritation, the respirator fit is inadequate.

The Community College of Rhode Island makes 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 the 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 the College, PLHCP, supervisor, or Program Administrator 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: and
When the employee, subsequently after passing a QLFT, notifies the College, Program Administrator, supervisor, or PLHCP that the fit of the respirator is unacceptable. That employee will be retested with a different respirator face piece.

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). The College ensures with written procedures that respirators are used properly in the workplace. The proper respirator use procedures based on OSHA 29 CFR 1910.134(g) are listed below:

Respirators with tight-fitting face pieces may not 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; or any condition that interferes with the face-to
If an employee wears corrective glasses or goggles or other personal protective equipment, such equipment must be 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, employees must 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)
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, the conti
Employees must 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; or if they detect vapor or gas breakthrough, changes in breathing resistance, or leakage of the facepiece: or 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, the respirator must be replaced or repaired before the employee can return to the work area. The College uses the following checklist to ensure that proper use procedures include coverage of OSHA requirements:

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 the continued effectiveness of the respirator will be reevaluated.

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

The College provides each respirator user with a respirator that is clean, sanitary, and in good working order. The College ensures that respirators are cleaned and disinfected using the procedures in Appendix B-2 of 29 CFR 1910.134 or those recommended by the respirator manufacturer. See those procedures below which are of equivalent effectiveness as Appendix B-2 of 29 CFR 1910.134.

The respirators are cleaned and disinfected at the following intervals:

Respirator type:	Are cleaned and disinfected at the following interval:
Issued for the exclusive use of an employee	As often as necessary to be maintained in a sanitary condition
Issued to more than one employee	Before being worn by different individuals
Maintained for emergency use	After each use
Used in fit testing and training	After each use

Storage of Respirators

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

Inspection of Respirators

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

Respirator type:	Inspected at the following frequencies:
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

Any one of the respirator inspections includes a check of the following:

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 or filters; and
Of electrometric parts for pliability and signs of deterioration.

Repairs to Respirators

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; and

Discarding of Respirators

Respirators that fail an inspection or are otherwise not fit for use and cannot be repaired must be discarded at the discretion of the Physical Plant Directors or the Chemical Safety Coordinator.

All filters, cartridges and canisters used in the workplace must be labeled and color-coded with the NIOSH approval label. The label must remain in place and be legible.

Training in Respirator Use

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 the employees are aware of the purpose of wearing respirators, and how they are to be worn is to train them. Employee training is an important part of the respiratory protection program and is essential for correct respirator use.

The training program provided is two-fold; it covers both the:

Respiratory hazards to which the employees are potentially exposed during routine and emergency situations, and
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 in the workplace. However, if an employee has received training within 12 months addressing the seven basic elements of respiratory protection (see "Seven basic elements" below) and the Community College of Rhode Island and the employee can demonstrate that he/she has knowledge of those elements, then that employee is not required to repeat such training initially.

The College does require all of the 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; or
Any other situation arises in which retraining appears necessary to ensure safe respirator use.

Seven Basic Elements:

Employees are trained sufficiently to be able to demonstrate knowledge of at least these seven elements: Employees will receive additional one-on-one training for each type of hazard or each new chemical they are exposed to.

Why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator.

The effects of respiratory hazards to which employees may be exposed.
Identity of the chemicals involved, what exposure levels there would be if no respiratory protection were being used, and what the potential health effects of such exposure would be if the respirator is not worn or not worn properly.
Inspection of the material safety data sheets for the hazardous chemicals that the chemical manufacturers are required to produce under Hazard Communication 29 CFR 1910.1200.

What the limitations and capabilities of the respirator.

How the respirator provides protection by either filtering the air or absorbing the vapor.
Limitations on the equipment such as prohibitions against using an air-purifying respirator in the event of an emergency with Immediate Danger to Life and Health (IDLH) atmospheres, and why air purifying respirators should never be used in such situations.

How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions.

Respirators do malfunction on occasion. If a malfunction occurs, the user must exit the area immediately and not re-enter until the problem has been corrected or the user has been fitted with a new properly working respirator.
College employees are generally not trained nor are they expected to deal with emergency situations involving toxic or irritating vapors. The Department of Security and Safety and college Police and the Chemical Safety Coordinator must be notified at once of any emergency situation. This procedure is outlined in the College's Emergency Response Plan.

How to inspect, put on, remove, use, and check the seals of the respirator.

The College is required to ensure that such inspections are performed but employees using the equipment may frequently be responsible for inspecting the respirators assigned to them. Demonstration of this process so employees are capable of recognizing any problems that may threaten the continued protective capability of the respirator.
Steps employees are to follow if they discover any problems during inspection, i.e., who this should be reported to and where they can obtain replacement equipment if necessary. Everyday respirator fit must be as close as possible to the fit obtained
Practice so employees can perform these tasks effectively. Positive and negative pressure face piece seal checks and other tests may be used. Employees must be trained regarding the appropriate tests to be used for the respirators they are wearing.

Procedures for maintenance and storage of the respirator.

Procedures to prevent damage, deformation or deterioration of the respirator during storage.

How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators.

Knowledge of the medical problems that may preclude employees from using some types of respirators or from wearing a respirator under certain workplace conditions to assure that the employee receives the protection intended by 29 CFR 1910.134. Examples include employees with histories of asthma, chronic bronchitis, pneumonia, lung cancer, and other conditions listed in 29 CFR 1910.134, Appendix C.
Medical information sufficient for employees to recognize the signs or symptoms of medical conditions (e.g., shortness of breath, dizziness) that may affect their use of respirators.

The general requirements of 29 CFR 1910.134.

The employer's obligations under the standard with respect to employee protection. The College is obligated to: Develop a written program; Select respirators properly; Evaluate respirator use; Correct deficiencies in respirator use; Conduct medical evaluations; Provide for the maintenance, storage, and cleaning of respirators: and retain and provide access to specific records.
The basic advisory information on respirators, as presented below is provided by the Program Administrator to employees who wear respirators when such use is not required by the regulations or by the College:

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. After discussion with an employee, and at the discretion of the Chemical Safety Coordinator, the College may provide a respirator for voluntary use. However, certain precautions must be taken to ensure that the respirator itself does not present a hazard.

The employee must read and heed all instructions provided by the manufacturer on use, maintenance, cleaning and care, and warnings regarding the respirators limitations.
Respirators certified for use to protect against the contaminant of concern must be chosen.. NIOSH, the National Institute for Occupational Safety and Health of the US Department of Health and Human Services, certifies respirators. A label or statement of certification should appear on the respirator or respirator packaging. It tells what the respirator is designed for and how much protection it gives.
Respirator must not be worn in atmospheres containing contaminants for which the respirator is not designed. For example, a respirator designed to filter dust particles will not protect against gases, vapors, or very small solid particles of fumes or smoke.

Respirator Program Evaluation

It is inherent in respirator use that problems with protection, irritation, breathing resistance, comfort, and other respirator-related factors occasionally arise in most respirator protection programs. Although it is not possible to eliminate all problems associated with respirator use, the College tries to eliminate as many problems as possible to improve respiratory protection and encourage employee acceptance and safe use of respirators. By having the Program Administrator and the Physical Plant Directors thoroughly evaluate and, as necessary, revise the Respiratory Protection Program, the College can eliminate problems effectively.

Program evaluation, performed semiannually by the program
administrator, involves the following:

Conducting evaluations of the workplace as necessary to ensure that the provisions of the current written program are being effectively implemented.
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; and Proper respirator maintenance.

Appendix 1--References

The following documents are helpful references:

29 CFR 1910.134, Respiratory Protection, and Appendices
42 CFR 84, Approval of Respiratory Protective Devices,
ANSI Z88.2, Respiratory Protection,
NIOSH Guide to Industrial Respiratory Protection-1987 (however, this may be out of date),
NIOSH Guide to the Selection and Use of Particulate Respirators Certified Under 42 CFR 84

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