Complying with OSHA's New Respirator Standard

Contributed by Mark Bordelon, Environmental Resources Management, Irvine, California

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This feature article was originally published in EM Online, an Internet Magazine for Environmental Managers. It is brought to you by ChemAlliance through an exclusive redistribution agreement with the Air & Waste Management Association (www.awma.org). Under the terms of this agreement, the article may not be copied, saved, e-mailed, sold, rewritten for broadcast, or redistributed in any form.

Copyright 1999, Air & Waste Management Association, All Rights Reserved

Introduction

Many workplace situations involve toxic substances for which engineering controls may be inadequate to control exposures. Respirators are used in these situations as a back-up method of protection. There are two major classes of respirators: (1) air-purifying to remove contaminants from the air, and (2) atmosphere-supplying to provide clean, breathable air from an uncontaminated source.

The Occupational Safety and Health Administration (OSHA) respirator standard requires that employers establish and maintain an effective respiratory program and that employees are responsible for wearing the respirator and complying with the program.1 This article reviews the major requirements of OSHA's standard on respiratory protection, as revised in 1998.

Background

In 1971, OSHA adopted the American National Standards Institute (ANSI) standard Z88.2-1969, Practices for Respiratory Protection, as well as ANSI Standard K13.1-1969, Identification of Gas Mask Canisters, as its standard for respiratory protection. In April 1971, OSHA promulgated the initial respiratory protection standard for the construction industry.2 On February 9, 1979, OSHA announced that 29 Code of Federal Regulations (CFR) 1910.134 would be formally recognized as also being applicable to the construction industry. In November 1994, OSHA issued a Notice of Proposed Rulemaking to revise 29 CFR 1910.134. Public hearings were held in 1995, and the Final Rule was published on January 8, 1998, in the Federal Register.3

The new respiratory standard became effective on October 5, 1998. The prior 1910.34 standard was retained, but redesignated as 1910.139. It applies only to respiratory protection against tuberculosis until OSHA has promulgated the final standard for Occupational Exposure to Tuberculosis.

One of OSHA's main goals in updating the standard was to incorporate new technology and current scientific knowledge regarding respiratory protection. Language in the new standard was also revised to make some requirements in the previous standard more understandable, thereby promoting more effective use of respirators.

The first section of the standard restates OSHA's long-standing policy that engineering and work practice controls should be the primary means used to reduce employee exposure to toxic chemicals, and that respirators should only be used if engineering or work practice controls are infeasible or while they are being implemented. Feasible engineering, administrative, or work practice controls must be instituted even though they may not be sufficient to reduce exposure to, or below, the permissible exposure limit. They must be used in conjunction with respirators whenever exposures exceed permitted levels.

What's New

Several important changes to the standard were made. In workplaces where respirator use is required, complying with the provisions of the new standard may present new challenges for employers. However, OSHA views the new standard as a benefit to employers and employees because it is expected to significantly reduce exposure of workers to toxic substances. OSHA is likely to enforce the new standard rigorously.

This article reviews some of the major components of the new regulation that are likely to impact employers' job health and safety programs regarding the use of respirators. Major provisions of the respiratory standard are summarized in Table 1.

Respiratory Protection Program

All worksite-specific procedures for the respirator program and documentation of compliance must be in writing. However, paragraph (c)(2)(ii) make sit clear that the written program need not address those employees who are not required to use respirators, but who voluntarily wear filtering facepiece respirators. For example, if the employer has determined that no hazard exists, but an employee asks the employer for a respirator because a "smell" is bothersome, then this is considered "voluntary use."

The standard requires that employers revise the program as necessary to reflect changes in the workplace or in respirator use. Changes would include different respirator choices, changes in fit testing, and change in work operations.

The employer has the flexibility to develop a corporate written program that would be applicable to all facilities. It must, however, include site-specific provisions to reflect different site conditions.

Respirator Selection

The selection of appropriate respirators must follow certain procedures. The standard's provision on respirator selection requires the employer to evaluate the respiratory hazard and other factors and select an appropriate device. The standard does not discuss specific protection factors. However, it does specify that supplied air devices are required in immediately dangerous to life and health (IDLH) atmospheres.

Under the new standard, employers are required to provide a respirator cartridge change schedule. A change schedule is the part of the written respirator program that says how often cartridges should be replaced and on which information this judgment is based. There are three valid ways to estimate the service life of a cartridge: (1) conduct experimental tests, (2) use the manufacturer's recommendation, or (3) use a mathematical model. It is no longer acceptable to rely on odor thresholds and other warning properties as the primary basis for determining the service life of gas and vapor cartridges and canisters.

The standard also requires that cartridges and canisters have an end-of-service-life indicator (ESLI). ESLIs are National Institute of Occupational Safety and Health (NIOSH) certified for only a few contaminants, under most conditions of use. Therefore, cartridges and canisters equipped with ESLIs can be used only if they are appropriate for the conditions of the employer's workplace. An example of a workplace condition that might adversely affect an ESLI is when a cartridge equipped with a moisture-dependent ESLI is used in an extremely dry atmosphere.

Medical Evaluation of Respirator Users Is Required

The employer must provide a medical evaluation to determine the employee's ability to use a respirator before the employee is fit tested or required to use the respirator in the workplace. The medical evaluation is required because use of a respirator puts physiological strain on the wearer. The employer must select a physician or other licensed health care professional (PLHCP) to perform the evaluation.

The employee must complete the medical questionnaire in Appendix C of the standard, or an equivalent form, during working hours and in a convenient location. The questionnaire is confidential; therefore, the employers may not look at the responses. If an employee does not understand the questionnaire, the employer must take action, such as having the PLHCP assist the employee in filling out the medical questionnaire, or go directly to a physical examination.

Supplemental information must be provided to the PLHCP, including the type and weight of respirator to be used, duration and frequency of use, expected physical work effort, additional protective equipment and clothing, and temperature and humidity extremes to be encountered.4 The employer must also provide the PLHCP with a copy of the employer's written respirator program and the respirator standard.

>The medical evaluation is performed by the PLHCP using the questionnaire, and a physical examination is performed if deemed appropriate. The standard does not specify pulmonary function or cardiovascular testing or examination, although such procedures are generally a routine part of a respirator medical certification.4

The PLCHP must provide a written recommendation to the employer and the employee that states the limitations on use of a respirator, and any necessary medical follow-up. A follow-up evaluation is required if a relevant medical condition exists, the employer determines the employee needs re-evaluation, or changes in workplace conditions necessitate a re-evaluation.

The employer must perform periodic medical evaluations on respirator users. The standard does not specify a schedule; however, re-evaluations should be performed at a reasonable frequency (every one or two years, for example) unless the PLHCP indicates a higher frequency.

Annual Employee Training and Fit Testing Fit testing is required when OSHA or the employer requires employees to wear tight-fitting respirators. Both negative pressure and positive pressure tight-fitting respirators must be tested. Self-contained breathing apparatuses (SCBAs) also require a fit test. Respirators that do not require a fit test include those worn when not required by OSHA or the employer, and loose-fitting respirators.

The employee must pass a fit test prior to initial use of the respirator. Additional fit tests are required whenever the employee reports, or when the employer, PLHCP, supervisor, or program administrator observes changes in the employee's physical condition that could affect respirator fit. If the employee changes to a different fitting facepiece, a new fit test is required. An annual fit test is required after the initial fit test.

One of the most significant changes to the respirator standard is the fit-test procedure. The employer must use one of the OSHA-accepted qualitative, or in some cases quantitative, fit-test protocols. OSHA-accepted protocols are found in Appendix A of the Respiratory Protection Standard. Any new fit- testing methods must first meet the acceptance requirements of Section II of Appendix A before they can be used. Parties with a new fit-test method must supply a detailed description of the method, as well as data from an independent government research laboratory, or from a study published in a peer-reviewed industrial hygiene journal supporting the new method's performance.

The standard requires that before employees are required to use any tight-fitting facepiece, they must be tested with the same make, model, style, and size of respirator that they will actually use.

Appendix A of the standard contains specific testing procedures for four qualitative fit tests (QLFTs) and three quantitative fit tests (QNFTs) (see sidebar). The employer may select the testing method; however, they must strictly follow the general requirements and the specific procedures for the selected method. A summary of acceptable fit-testing methods for various types of respirators is provided in Table 2.

Each of these protocols, both QLFT and QNFT, requires the use of the specific procedure, plus the general protocol and exercise regimen, to complete the test. For example, when administering one of the qualitative tests, these general rules apply:

The exercise regimen performed while the respirator is donned includes normal breathing, deep breathing, turning head side to side, moving head up and down, grimacing (QNFT only), bending over, and talking. Often the person being tested is asked to read the "Rainbow Passage":

"When the sunlight strikes raindrops in the air, they act like a prism and form a rainbow. The rainbow is a division of white light into many beautiful colors. These take the shape of a long round arch, with its path high above, and its two ends apparently beyond the horizon. There is, according to legend, a boiling pot of gold at one end. People look but no one ever finds it. When a man looks for something beyond reach, his friends say he is looking for the pot of gold at the end of the rainbow. "

Facepiece Seal Check

Employees using tight-fitting facepiece respirators are required to perform a user seal check each time they put on the respirator. They must use the procedures in Appendix B-1 of the standard or procedures recommended by the respirator manufacturer which the employer demonstrates are as effective as OSHA's procedures. Note that a fit test is a method used to select the right size respirator for the user. A user seal check is a method to verify that the user has correctly put on the respirator and adjusted it to fit properly.

Respirator Cleaning and Disinfection, Storage, Inspection, Maintenance, and Repair

The standard emphasizes the requirement that employers provide for the cleaning and disinfecting, storage, inspection, and repair of respirators used by their employees. The employer is allowed to choose the cleaning and disinfecting program that best meets the requirements of the standard and the particular circumstances of the workplace. It is OSHA policy that if the employer elects to have employees clean their own respirators, the employer must provide the cleaning and disinfecting equipment, supplies, and facilities, as well as time for the job to be done.

Disposable respirators cannot be disinfected, and are therefore assigned to only one person. Disposable respirators must be discarded if they are soiled, physically damaged, or reach the end of their service life. Replaceable filter respirators may be shared, but must be thoroughly cleaned and disinfected after each use before being worn by a different person, using the procedures in Appendix B-2 of the standard.

Powered Air Purifying Respirators

The revised standard requires that employers provide powered air purifying respirators if an employee is medically unable to wear a negative-pressure device as determined during the medical evaluation. Powered air purifying respirators are supplied with filtered air through a blower powered by a belt-mounted battery pack. This requirement was previously associated with the asbestos standard because of the frequency of breathing-impaired workers in the insulation and abatement industry.4

Periodic Program Evaluation

Employers must review the written program and revise, as necessary, the written program elements specified in Paragraph (c)(1) of the standard when workplace conditions affecting the use of respirators change. An annual written program review is not required; instead, a program review and revision are required as necessary based on workplace changes. Evaluation frequency is to be based on program complexity and factors such as the nature and extent of workplace hazards, types of respirators in use, variability of workplace processes and operations, number of respirator users, and worker experience in the use of respirators. The employer must review respirator use in the workplace with sufficient frequency to ensure that continuous, successful implementation of all written respirator program elements prescribed under Paragraph (c) are being achieved.

Areas that require re-evaluation include whether the respirator program is achieving proper respirator fit; whether the appropriate respirators are being selected; and the proper use and maintenance of respirators. If respirators are not being used properly, the employer is required to correct any problems found during the assessment.

Program Administrator

Employers are required to appoint a program administrator to oversee the respiratory protection program and conduct the required evaluations of program effectiveness (i.e., fit testing and training). The standard does not provide specific guidance on the qualifications for this position. The training and experience are required to be adequate for the complexity of the particular workplace program. Use of Respirators

In the new standard, OSHA has emphasized that in IDLH atmospheres, the use of respirators is subject to special precautions and selection criteria.

In many industrial IDLH situations, only one respirator user is exposed to the IDLH atmosphere at a time, which means that a single-standby person can easily monitor that employee's status (when needed, the standard requires more than one employee outside). Even in situations where more than one respirator user is inside an IDLH atmosphere, a single-standby person can often provide adequate communication and support. For example, in a small pump room or shed, even though two or three employees may be inside an IDLH atmosphere performing routine maintenance activities such as changing pump seals, one standby person can observe and communicate with all of them. In this type of situation, one standby person is adequate and appropriate, as long as the employee outside is able to perform an effective rescue.

However, there are instances in which more than one standby person is needed.5 The requirement for standby personnel is performance-oriented: "One employee or, when needed, more than one employee must be located outside the IDLH atmosphere." For example, to clean and paint the interior of a multi-portal water tower, a process that often generates a deadly atmosphere as a result of cleaning solution and paint solvent vapors, employees often enter the tower through different portals to work on different levels. In such a situation, there will be a need for good communications at each entry portal, and more than one standby person would be needed to maintain adequate communication accessibility.

The employer has flexibility in determining who will respond to such emergency rescue situations. The employer will have determined in advance, as part of the written respirator program's worksite-specific procedures, the procedures that standby personnel will follow and whom they specifically need to notify in rescue situations.

Standby personnel must have appropriate equipment to minimize the danger to themselves during rescue efforts. They must be equipped with pressure demand or other positive pressure SCBA, or a pressure demand or other positive pressure supplied-air respirator with auxiliary SCBA.

Summary

The revised standard contains many new provisions. It is important to start with the requirements related to the most serious hazards in your workplace first. Except for medical evaluations, which previously were only recommended, all of the provisions discussed were requirements of the superceded respirator regulation.

No attempt has been made to address all aspects of the standard in this article. Consult the Federal Register for the complete text of the standard. Sources of additional information are listed in the information box accompanying this article.

Contact Information

Mark Bordelon is a hydrogeologist with Environmental Resources Management, Irvine, California. His areas of interest include environmental site assessment, risk assessment, and regulatory compliance consulting. E-mail: mark_bordelon@ermwest.com.

Acknowledgments

Terry Armstrong is thanked for her careful review and helpful comments on this article.

Various OSHA publications such as fact sheets, news releases, directives, and information booklets were used in preparing this article. OSHA is thanked for making these publications available.

References

1. OSHA's regulations cover general, construction, and maritime industries.

2. Title 29 Code of Federal Regulations (CFR) 1926.103.

3. See Title 29 CFR, Part 1910.134.

4. California Regwatch January 1999.

5. An OSHA compliance directive (CPL 2-0.120) discusses the "two-in/two-out" requirement, which mandates that at least two firefighters must be stationed outside during interior structural firefighting, prepared to rescue firefighters inside.

Where to Find Additional Information

OSHA Standard

OSHA Directive

NIOSH

State Programs