Central Michigan University
College of Science and Technology
Respiratory Protection Program
This Respiratory Protection Program has been written in accordance with the Michigan Occupational Safety and Health Administration’s (MIOSHA) R 325.6 as adopted from Occupational Safety and Health Administration’s 29 Code of Federal Regulations (CFR) 1910.134. The signatures below acknowledge the significance of the Respiratory Protection Program, and reflect both individual and collective support for the program on behalf of the College.
Jennifer Walton, Safety Coordinator Date
College of Science and Technology
Robert Kohrman, Dean Date
College of Science and Technology
TABLE OF CONTENTS
SECTION I: INTRODUCTION
D. Management Responsibilities
SECTION II: PROCEDURES FOR SELECTING RESPIRATORS
A. Evaluation Of The Workplace
B. Determining The Appropriate Respirator
SECTION III: MEDICAL EVALUATIONS
SECTION IV: FIT TEST PROCEDURES
SECTION V: PROCEDURES FOR PROPER USE OF RESPIRATORS
SECTION VI: PROCEDURES FOR MAINTENANCE OF RESPIRATORS
E. Identification of Filters, Cartridges, and Canisters
SECTION VII: PROCEDURES TO ENSURE ADEQUATE AIR QUALITY FOR ATMOSPHERE-SUPPLYING RESPIRATORS
B. Requirements For Breathing Air Compressors
SECTION VIII: TRAINING OF EMPLOYEES FOR POTENTIAL HAZARDS
SECTION IX: TRAINING OF EMPLOYEES IN THE PROPER USE OF RESPIRATORS
SECTION X: PROCEDURES FOR EVALUATING THE EFFECTIVENESS OF THE PROGRAM
SECTION XI: RECORDKEEPING
SECTION XII: VOLUNTARY USE OF RESPIRATORS AND DUST MASKS
APPENDIX A: RESPIRATORY HAZARD EVALUATION
APPENDIX B: MEDICAL EVALUATION REQUEST/QUESTIONNAIRE
APPENDIX C: MANDATORY FIT TEST PROCEDURES
APPENDIX D: MANDATORY USER SEAL CHECK PROCEDURES
APPENDIX E: RESPIRATOR PROGRAM INSPECTION TAG
APPENDIX F: IDENTIFICATION LABELS AND COLOR CODES
APPENDIX G: TESTING THE COMPETENCY OF EMPLOYEES
APPENDIX H: MANDATORY INFORMATION FOR EMPLOYEES USING RESPIRATORS WHEN NOT REQUIRED UNDER THE STANDARD
APPENDIX I: PROCEDURES FOR CLEANING AND SANITIZING RESPIRATORS
APPENDIX J: RESPIRATORY PROTECTION PROGRAM CHECKLIST
APPENDIX K: DEFINITIONS
This Respiratory Protection Program has been written in accordance with the Michigan Occupational Safety and Health Administration’s (MIOSHA) R 325.6 as adopted from Occupational Safety and Health Administration’s 29 Code of Federal Regulations (CFR) 1910.134. Its goal is to implement procedures for protecting the employees of the College of Science and Technology from harmful airborne contaminants through the use of a variety of types of personal protective equipment (PPE), such as masks and respirators. In addition, exposure to health risks will be reduced through training in hazard recognition.
As directed in the Occupational Health Standards for Respiratory Protection, the scope is to control occupational diseases caused by breathing air contaminated with harmful dusts, fumes, mists, gases, smokes, sprays, or vapors. The primary objective shall be to prevent atmospheric contamination through engineering control measures. When effective engineering controls are not feasible, or while they are being instituted, appropriate respirators shall be used pursuant to these rules. This program applies to all employees of the College of Science and Technology.
The Safety Coordinator for the College of Science and Technology has overall responsibility for the administration and implementation of the Respiratory Protection Plan.
D. Management Responsibilities
Respirators shall be provided by the university at no cost to the employee. Respirators shall comply with all OSHA statutory and regulatory requirements, under routine and reasonably foreseeable emergency situations. Atmospheric testing will be conducted by the University when necessary to characterize potential atmospheric hazards to the employee. The University shall provide respirators, training, and medical evaluations for employees when the atmospheric hazard cannot be eliminated through engineering controls.
The employee is responsible for wearing the respirator, and any other personal protective equipment, required for the atmosphere that they are exposed to. Failure to do so may lead to disciplinary action.
SECTION II: PROCEDURES FOR SELECTING RESPIRATORS
A. Evaluation of the Workplace
An evaluation of the workplace will be conducted in accordance with Appendix A of this document as required by the standards, to determine the necessary factors for the selection of respirators. A respirator shall be used only after feasible engineering controls and work practices have been instituted in order to minimize employee exposure to hazardous substances.
a. Evaluation of reasonable exposure – The University is required to evaluate respiratory hazards in the workplace, identify relevant workplace and user factors, and base respirator selection on these factors.
b. Identification of state and physical form – The respirator shall be appropriate for the chemical state and physical form of the contaminant.
c. Immediately Dangerous to Life and Health (IDLH) - When the evaluation is conducted and where a reasonable estimate of exposure to the employee can not be determined, the atmosphere shall be considered to be Immediately Dangerous to Life and Health. This means that the atmosphere poses an immediate threat to life, would cause irreversible adverse health effects, or would impair an individual’s ability to escape from a dangerous atmosphere. All oxygen-deficient atmospheres shall be considered IDLH.
B. Determining the Appropriate Respirator
Respirator selection considers two categories of respirators; air-purifying and atmosphere-supplying respirators, which include types that operate under positive or negative pressure. An air-purifying respirator protects the user by removing contaminants from inhaled air through the use of filters, cartridges, or canisters, whereas a positive-pressure respirator delivers a steady stream of purified air. A negative-pressure respirator (tight fitting) is regulated so that air is delivered whenever the face-piece pressure drops below a certain preset level. Per NIOSH, the Assigned Protection Factor (APF) is 10 for any air-purifying half mask, and 50 for any air-purifying full mask respirator. Respirator recommendations may be guided by the APF, the airborne concentration and Recommended Exposure Limit (REL).
APF > workplace airborne concentration / recommended exposure limit (REL)
a. In compliance with the standard and after the factors have been determined for the selection of respirators, an appropriate respirator will be selected based on the respiratory hazard the employee is exposed to.
b. NIOSH certified respirators will be selected that provide adequate protection of the health of the employee, are appropriate for the atmosphere and are in compliance with the OSHA statutory and regulatory requirements.
c. For atmospheres that are considered to be Immediately Dangerous to Life and Health (IDLH), a full face-piece pressure demand Self Contained Breathing Apparatus (SCBA) certified by NIOSH for a minimum service life of thirty minutes or a combination full face-piece pressure demand Supplied-Air Respirator (SAR) with auxiliary self contained air supply will be used.
d. Respirators shall be provided in sufficient numbers, sizes and models so that the respirator is acceptable to, and correctly fits the user.
e. The selection of a proper respirator for a given situation shall take into consideration the following factors:
1. Nature of the hazard, including the chemical and physical properties of the air contaminant, concentration of the toxic material, and the established exposure limits of the toxic material.
2. Characteristics of the hazardous operation.
3. The period of time the respirator is used.
4. The respirator characteristics, capabilities and limitations.
f. Respirators shall be equipped with an end-of-service-life indicator (ESLI) certified by NIOSH for the contaminant, or if there is no ESLI appropriate for conditions, supervisors should implement a change schedule for canisters and cartridges for the particular contaminant encountered, taking into account the volatility of the chemical, the cartridge use/nonuse patterns, and desorption data, if available, to ensure that cartridges are changed before the end of their service life.
SECTION III: MEDICAL EVALUATIONS
The University will provide a medical evaluation to employees at no cost to determine the employees’ ability to use a respirator before being fit tested or required to use a respirator in the workplace. The University is not required to continue medical evaluations when the employee is no longer required to use the respirator.
a. Employees will not be assigned to tasks requiring use of respirators unless they have received a physical examination by a licensed physician, which may include a pulmonary function test, EKG and chest X-ray, if determined by the physician. The CHIP Facility, working with Central Occupational Medicine Program (COMP), will arrange for a physician who shall determine the physical and respiratory conditions of the user. The respirator user’s medical status will be reviewed on a two-year basis or when the user’s condition changes significantly.
b. Medical Evaluation Questionnaire (Appendix B) shall be administered and completed confidentially and provided to the health care professional who will review as part of their evaluation. This is a confidential questionnaire and will not be provided to or reviewed by the University. This information does not need to be provided for each subsequent evaluation if the information remains the same.
c. Follow-up examinations will be provided by the University for any employee whose examination demonstrates the need for it to include any medical tests or consultations deemed necessary by the Physician or other licensed health care professional (PLHCP).
d. The University must provide to the PLHCP the following information:
1. Type and weight of the respirator to be used by the employee.
2. Duration and frequency of respirator use (including use for rescue and escape).
3. Expected physical work effort.
4. Additional protective clothing and equipment to be worn.
5. Temperature and humidity extremes that may be encountered.
6. Current copy of the written Respiratory Program.
e. The University will obtain a written recommendation regarding the employee’s ability to use a respirator from the PLHCP that will provide the following information:
1. Any limitations on respirator or personal protective equipment use related to the medical condition of the employee, or relating to the workplace conditions in which the PPE will be used, including whether or not the employee is medically able to use them.
2. The physician’s opinion as to whether the employee has any detected medical conditions that would place the employee at an increased risk of health impairment from exposure to harmful airborne matter or using a respirator.
3. The need, if any, for follow-up medical evaluations.
4. A statement that the PLHCP has provided the employee with a copy of the PLHCP’s written recommendation and provided an opportunity to discuss the results.
5. The physician’s opinion shall not include specific findings or diagnosis unrelated to occupational exposure to harmful airborne matter or to use of the respirator.
f. Additional medical evaluations will be provided when:
1. The employee reports medical signs or symptoms that are related to ability to use a respirator.
2. A PLHCP, supervisor, or the respirator program administrator determines that an employee needs to be reevaluated.
3. Information from the respiratory program, including observations made through fit testing and program evaluation, indicates a need for employee evaluation.
4. A change occurs in workplace conditions (physical work effort, protective clothing, and temperature) that may result in a substantial increase in the physiological burden on an employee.
SECTION IV: FIT TEST PROCEDURES
Before an employee is required to use any respirator, the University shall ensure that the respirator issued to the employee exhibits the least possible leakage and that the respirator is fitted properly. The employee must be fit tested with the same make, model, style, and size of respirator that will be used.
a. The University will ensure that the employees using a tight-fitting face-piece respirator pass an appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT). Mandatory fit test procedures are found in Appendix C.
Qualitative Fit Test – pass/fail test to assess the adequacy of a respirator fit that relies on the individual’s response to the test agent. This test may only be used to fit test negative pressure air-purifying respirators that must achieve a fit factor of 100 or less.
Quantitative Fit Test – an assessment of adequacy of a respirator fit by numerically measuring the amount of leakage into the respirator. This test is used to fit test respirators with a fit factor of 100 or greater for tight-fitting half face-pieces, or 500 or greater for tight fitting full face-pieces.
b. The employee shall be tested prior to initial use of respirator, whenever a different respirator face-piece (size, style, model or make) is used, and at least annually thereafter.
c. Additional fit test will be conducted whenever the employee, supervisor, program administrator or PLHCP makes visual observations in the employee’s physical condition that could affect respirator fit such as weight change or significant facial scarring in the area of the face-piece seal.
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d. The employee shall be given the opportunity to wear the assigned respirator for one week. If the respirator does not provide a satisfactory fit during actual use, the employee may request another fit test which shall be performed immediately, or request a different respirator. If the employee finds the respirator unacceptable, they will be provided an opportunity to select a different respirator face-piece and to be retested.
e. Respiratory difficulty during tests - If an employee exhibits difficulty in breathing during the tests, she or he shall be referred to a physician trained in respiratory diseases or pulmonary medicine to determine whether the employee can wear a respirator while performing their duties.
Every respirator wearer shall receive fitting instructions including demonstrations and practice in how the respirator should be worn, how to adjust it, and how to determine if it fits properly. Respirators shall not be worn when conditions prevent a good face seal. Such conditions may be a growth of beard, sideburns, a skull cap that projects under the face piece, or temple pieces on glasses. Also, the absence of one or both dentures can seriously affect the fit of a face piece.
The face piece fit shall be checked by the wearer each time he/she puts on the respirator. This will be done in accordance with the Manufacturer’s face piece fitting instructions.
SECTION V: PROCEDURES FOR PROPER USE OF RESPIRATORS
The University shall consider and prohibit the use of tight-fitting face-pieces to be worn by employees who have:
a. Facial hair that comes between the sealing surface of the face-piece and the face or that interferers with valve function.
b. Any condition that interferes with the face-to-face-piece seal or valve function.
c. Corrective glasses, goggles or other personal protective equipment that interferes with the seal of the face-piece to the face.
Employees will perform a user seal check each time they put on a respirator using the procedures in Appendix D or procedures recommended by respirator manufacturer.
SECTION VI: PROCEDURES FOR MAINTENANCE OF RESPIRATORS
Respirators shall be stored in a convenient, clean and sanitary location, so as to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals, and they should be packed or stored to prevent deformation of the face-piece and exhalation valve.
a. Respirators shall be kept accessible to the work areas.
b. Respirators shall be stored according to applicable manufacturer instructions.
Respirators shall be cleaned and disinfected at the following intervals:
a. Respirators issued for exclusive use of an employee shall be cleaned and disinfected as often as necessary to be maintained in a sanitary condition.
b. Respirators issued to more than one employee shall be cleaned and disinfected before being worn by different individuals.
c. Respirators maintained for emergency use shall be cleaned and disinfected after each use.
d. Respirators used in fit testing and training shall be cleaned and disinfected after use.
e. Procedures for cleaning and sanitizing respirators are provided in Appendix I.
Respirators will be inspected for function, tightness of connections, and the condition of the various parts including, but not limited to, the face-piece, head straps, valves, connecting tube, cartridges, canisters/filters, and all elastomeric parts for pliability and signs of deterioration. Respirators will be inspected at the following intervals:
a. Respirators used in routine situations shall be inspected before each use and during cleaning.
b. Respirators maintained for use in emergency situations shall be inspected at least monthly and in accordance with the manufacturer’s recommendations and checked for proper function before and after each use.
c. Emergency escape-respirators shall be inspected before being carried into the workplace for use. It will be certified by documenting the date the inspection was performed, name and signature of the person performing the inspection, serial number, any findings, and required remedial actions on the tag (Appendix E) and attached to the storage compartment of the respirator. This information will be maintained on file with the department Safety Coordinator. Currently there is no application for emergency escape respirators in the College of Science and Technology.
d. Self-Contained Breathing Apparatus (SCBA) shall be inspected monthly.
e. Air and oxygen cylinders shall be inspected monthly, maintained in a fully charged state, and recharged when the pressure falls to 90% of the manufacturers recommended pressure level.
Respirators that fail inspection or that are found to be defective will be removed from service immediately, discarded, repaired or adjusted in accordance to the following procedures:
a. Only trained personnel that use the manufacturer’s NIOSH-approved parts are authorized to perform repairs or adjustments to respirators, regulators, alarms or valves.
b. All repairs will be made according to the manufacturer’s recommendations and specifications for the type and extent of repairs performed.
E. Identification of Filters, Cartridges, and Canisters
All filters, cartridges and canisters will be labeled and color coded with a NIOSH approval label. The label will not be removed and will remain legible at all times. If the label is not legible, the filter, cartridge, or canister shall be pulled from service and given to the department Safety Coordinator for proper disposition. Identification of labels and color codes are found in Appendix F.
SECTION VII: PROCEDURES TO ENSURE ADEQUATE AIR QUALITY FOR ATMOSPHERE-SUPPLYING RESPIRATORS
The University is required to provide the user of an atmosphere-supplying respirator with high purity breathing gases. Compressed and liquid oxygen shall meet the United States Pharmacopoeia requirements for medical or breathing oxygen. Compressed oxygen is not used in atmospheric-supplying respirators that have previously used compressed air. Compressed breathing air shall meet at least the requirements for Grade D breathing air described in ANSI/Compressed Gas Association Commodity Specification for Air, G-7.1-1989, to include:
a. An oxygen content of 19.5 – 23.5%. Oxygen concentrations greater than 23.5% are used only in equipment designed for oxygen service or distribution.
b. Condensed hydrocarbon content of 5 milligrams per cubic meter of air or less
c. Carbon monoxide (CO) content of 10 ppm or less
d. Carbon dioxide content of 1,000 ppm or less
e. Lack of noticeable odor
B. Requirements For Breathing Air Compressors
The University is responsible for ensuring that compressors that are used to supply breathing air to respirators are constructed and situated in a manner to prevent entry of contaminated air.
a. Minimize moisture content so that the dew point at 1 atmosphere pressure is 10 degrees F (5.56 deg. C) below ambient temperature.
b. Have suitable in-line air-purifying sorbent beads and filters to further ensure breathing air quality. Sorbent beads and filters shall be maintained and replaced or refurbished periodically following the manufacturers instructions.
c. Have a tag (Appendix E) containing the most recent change date, name and signature of the person authorized to make the change.
d. For compressors that are not oil-lubricated, the carbon monoxide levels in the breathing air shall not exceed 10 ppm.
e. For oil-lubricated compressors, a high-temperature or carbon monoxide alarm, or both, will be used to monitor carbon monoxide levels. If high-temperature alarms are used, air supply will be monitored at intervals determined by the Safety Coordinator to prevent carbon monoxide in the breathing air from exceeding 10 ppm.
f. Ensure that breathing air couplings are incompatible with outlets for nonrespirable worksite air or other gas system. No asphyxiating substance shall be introduced into the breathing air lines.
g. Ensure that all breathing air containers are marked in accordance with the NIOSH respirator certification standard, 42 CFR part 84.
SECTION VIII: TRAINING OF EMPLOYEES FOR POTENTIAL HAZARDS
The University shall provide training to its employees that are required to wear respirators. This training will be conducted at least annually or more often as deemed necessary by supervisors and the Safety Coordinator. At a minimum, the following elements will be included:
a. Training will be conducted in a manner that is understandable to the employee.
b. Training shall be provided prior to the employee being required to wear the respirator in the workplace.
c. Retraining shall be administered annually (no later than 12 months from the date of the previous training) or if the following situations occur:
1. A change in the workplace or type of respirator renders training obsolete.
2. Inadequacies in the employee’s knowledge or use of the respirator indicate the employee has not retained the requisite skill.
3. Any situation arises in which retraining appears necessary to ensure safe respirator use.
SECTION IX: TRAINING OF EMPLOYEES IN THE PROPER USE OF RESPIRATORS
At a minimum, the employee must be able to demonstrate knowledge of the following:
a. Why the respirator is necessary and how the proper fit, usage, or maintenance can compromise the protective effect of the respirator.
b. What the limitations and capabilities of the respirator are.
c. How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions.
d. How to inspect, put on and remove, use, and check the seals of the respirator.
e. What the procedures are for maintenance and storage of the respirator.
f. How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators.
Appendix G of this program provides a means of testing the competence of users that will be maintained on file with the Safety Coordinator in compliance with Section XI for Recordkeeping. When the Safety Coordinator determines that the employee can successfully demonstrate the ability to perform their duties in a safe manner and in accordance with these procedures, they will be provided with a signed wallet card allowing them to start wearing a respirator. This card will be updated each time the employee is evaluated.
SECTION X: PROCEDURES FOR EVALUATING THE EFFECTIVENESS OF THE PROGRAM
The University will conduct evaluations of the workplace to ensure that the respiratory program has been properly implemented and to consult with employees to ensure that they are using respirators properly. The evaluations will include:
a. An evaluation that ensures that the provisions of the program are being effectively implemented.
b. Regular consultation with employees required to wear respirators to assess the employees’ views on program effectiveness and to identify any problems. Any problems that are identified during the assessment shall be corrected. Factors to be assessed include:
1. Respirator fit (including the ability to use the respirator without interfering with effective workplace performance).
2. Appropriate respirator selection for the hazards to which the employee is exposed.
3. Proper respirator use under the workplace conditions the employee encounters.
4. Proper respirator maintenance and storage.
5. Employees’ acceptance of the respirator and program.
The university is required to maintain written information regarding medical evaluations, fit testing, and the respirator program. This information will facilitate employee involvement in the respiratory program, assist the University in auditing adequacy of the program, and provide a record for compliance to the standards. The following will be retained by the employer:
a. Records of medical evaluations and Physician opinions.
b. Record of qualitative and/or quantitative fit testing administered to employees. They must contain:
1. Name or identification of employee tested
2. Type of fit test performed
3. Specific make, model, style, and size of respirator tested
4. Date of test
5. Pass/Fail results for QLFT or the fit factor and strip chart recording or other recording of the test results for QNFT.
c. Fit test records shall be retained for respirator users until the next fit test is administered.
d. Current written copy of the respirator program.
e. Any employee medical complaints related to potential exposure.
SECTION XII: VOLUNTARY USE OF RESPIRATORS AND DUST MASKS
Any employee who voluntarily wears a respirator when a respirator is not required under the standard is subject to the medical evaluation, cleaning, maintenance, and storage elements of this program, and must be provided with the form found in Appendix H.
Employees who voluntarily wear filtering face-pieces (dust masks) are not subject to the medical evaluation, cleaning, storage, and maintenance provisions of this program, however, they must be provided with the form found in Appendix H.