Complying with OSHA's New Respirator Standard
Table 1. Major Requirements of OSHA's Respiratory Protection Standard (29 CFR 1910.134)

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

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Permissible Practice

Paragraphs (a)(1) and (a)(2) are essentially unchanged from corresponding paragraphs of prior standard. Paragraph (a)(2) requires employers to provide employees with respirators that are "applicable and suitable" for the purpose intended "when such equipment is necessary to protect the health of the employee."

Definitions

Paragraph contains definitions of important terms used in the regulatory text. Previous respiratory protection standard contained no definitions.

Respiratory Protection Program
  • Must designate qualified program administrator to oversee the program.
  • Must provide respirators, training, and medical evaluations at no cost to the employee.
  • OSHA has prepared a Small Entity Compliance Guide containing criteria for selection of a program administrator and a sample program.
Selection of Respirators
  • Must select a NIOSH-certified respirator, which must be used in compliance with the conditions of its certification.
  • Employers are required to supply a respirator cartridge change schedule.
  • Must identify and evaluate respiratory hazards in the workplace, including a reasonable estimate of employee exposures and identification of the contaminant's chemical state and physical form.
  • Where exposure cannot be identified or reasonably estimated, the atmosphere shall be considered IDLH (which requires use of approved respirators).
  • Respirators for non-IDLH atmospheres:
    • For protection against gases and vapors, the employer shall provide:
    • an atmosphere-supplying respirator; or
    • an air-purifying respirator, provided that the respirator is equipped with an end-of-service-life indicator (ESLI) certified by NIOSH for the contaminant.
  • For protection against particulates, the employer shall provide:
    • an atmosphere-supplying respirator; or
    • an air-purifying respirator equipped with high-efficiency particulate air (HEPA) filters certified by NIOSH under 30 CFR Part 11 or with filters certified for particulates under 42 CFR Part 84; or
    • an air-purifying respirator equipped with any filter certified for particulates by NIOSH for contaminants consisting primarily of particles with mass median aerodynamic diameters of at least 2 micrometers.
Medical Evaluation
  • Must provide medical evaluation to determine employee's ability to use a respirator, before fit testing and use.
  • Must identify a PLHCP to perform medical evaluations using a medical questionnaire or an initial medical examination that obtains the same information as the medical questionnaire. Must obtain a written recommendation regarding the employee's ability to use the respirator from the PLHCP.
  • Periodic review of medical status is required.
Fit Testing
  • All employees using a negative or positive pressure tight-fitting facepiece respirator must pass an appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT).
  • Fit testing is required prior to initial use, whenever a different respirator facepiece is used, and at least annually thereafter. An additional fit test is required whenever employee reports, or the employer or PLHCP makes visual observations of, changes in the employee's physical condition that could affect respirator fit (e.g., facial scarring, dental changes, cosmetic surgery, or an obvious change in body weight).
  • The fit test shall be administered using an OSHA-accepted QLFT or QNFT protocol, as contained in mandatory Appendix A.
Use of Respirators
  • Tight-fitting respirators shall not be worn by employees who have facial hair or any condition that interferes with the face-to-facepiece seal or valve function.
  • Employees shall perform a user seal check each time they put on a tight-fitting respirator using the procedures in mandatory Appendix B-1 or equally effective manufacturer's procedures.
  • Procedures for respirator use in IDLH atmospheres are stated. 
Maintenance and Care of Respirators
  • Must clean and disinfect respirators using the procedures in Appendix B-2, or equally effective manufacturer's procedures.
Breathing Air Quality and Use
  • Compressed breathing air shall meet the requirements for Type 1-Grade D breathing air as described in ANSI/CGA Commodity Specification for Air, G-7.1-1989.

Identification of Filters Cartridges, and Canisters
  • All filters, cartridges, and canisters used in the workplace must be labeled and color coded with the NIOSH approval label.
  • The label must not be removed and must remain legible.
Training and Information
  • Must provide effective training for respirator uses prior to initial use.
  • Basic advisory information in Appendix D shall be provided to employees wearing respirators when use is not required.
Program Evaluation
  • Employer must conduct evaluations of the workplace as necessary to ensure proper implementation of the program, and consult with employees to ensure proper use.
Record Keeping
  • Records of medical evaluations must be retained and made available per 29 CFR 1910.1020.
  • A record of fit tests must be established and retained until the next fit test.
  • A written copy of the current program must be retained.

This table is a supplement to: Complying with OSHA's New Respirator Standard

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

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.

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