Elements of Respiratory Protection Program

Engineering controls and safe work practices are the primary means to prevent employee overexposure to chemicals and other inhalation hazards. However, when these controls are not feasible or available, then wearing a respirator may be necessary.  When respiratory protection must be used, OSHA’s Respiratory Protection Standard (RPS) (29 CFR 1910.134) must be followed.  Per the RPS a written respiratory protection program (RPP) with worksite-specific procedures for respirator use must be developed. The following are the core elements of a respiratory protection program:

  1. Procedures for selecting respirators for use in the workplace;
  2. Medical evaluations of employees required to use respirators;
  3. Fit testing procedures for tight-fitting respirators;
  4. Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations;
  5. Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators;
  6. Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators;
  7. Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations;
  8. Training of employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance; and
  9. Procedures for regularly evaluating the effectiveness of the program.

A respirator program administrator will need to be designated to develop and oversee the site specific aspects of the respirator program.  This person may be a supervisor, principal investigator, site safety contact, or other individual who is assigned and has the authority to address safety related issues at their specific work site.  The program administrator has the authority to assign responsibility and accountability to others within their work group for implementing aspects of this program.  NCSU’s Respiratory Protection Program can be used as the site specific written program if the forms and documents included in the appendices I-VI are completed and maintained up to date.  EHS will provide assistance and training to the program administrator in the development of the site specific program.

Respiratory Exposure Hazard Assessment and Selection

The mandatory use of respirators can be based on exposure to hazardous substance above the occupational exposure limit (PEL, TLV, etc.), specific regulations (i.e. asbestos, lead,),  or a policy determination has been made that employees will be required to wear one during certain times, activities, or tasks.  An example of the latter is, healthcare workers are required by policy to wear filtering-facepiece respirators (N-95) for protection from airborne infectious agents (example: flu).

The initial step in the process is respiratory exposure hazard assessment. A respiratory exposure hazard evaluation for each operation, process, or work area will need to be conducted to determine if respiratory protection is warranted or needed.  This can be done by completing the NCSU Environmental Health and Safety’s (EHS)  Respiratory Exposure Hazard Questionnaire (REHQ) . The first part of the questionnaire (1-18) is completed by the site supervisor or safety representative.  Next this form is then forwarded to EHS Occupational Health for review and completions (19-24). If it’s determined that respiratory protection is warranted EHS will stipulate what type of respirator(s) (Filtering Facepiece, half face, SCBA, etc…) is appropriate for the specific exposure hazard.  The site program administrator will keep a copy of the completed REHQ or record summary on hazard evaluation and respiratory inventory tables (See Appendices )

Respirator selection requires correctly matching the respirator with the hazard, the degree of hazard, and the user.  The following guidance and selections factors are used in this process:

All respirators must be certified by the National Institute for Occupational Safety and Health (NIOSH) and shall be used in accordance with the terms of that certification.

Medical Evaluation

Employees who use respirators must be able to tolerate the physical and psychological stress imposed by respirator use. Employees will not be allowed to wear respirators until a physician or other licensed health care professional (PLHCP) has determined that they are medically able to do so. Any employee refusing the medical evaluation cannot work in an area requiring respirator use.  The only exception to this medical evaluation is voluntary or comfort use of filtering facepiece (N-95) respirators.

The following table provides a summary on the types of respirator, example uses, medical evaluation, and frequency of medical evaluations for NCSU respirator users:

 

Respirator Types Use Examples Medical Requirements Frequency
Filtering-Facepiece (N-95) (Voluntary Use) Lawn mowing, Housekeeping, & Other Non-Hazardous Dust Exposures Complete the Filtering Facepiece Respirator Form .Complete the Employee Voluntary Use Attestation. Initial only
Filtering-Facepiece (N-95) (Required Use) Healthcare, Infectious Agents, Allergen, Silica, & Other  Dust Exposures Complete the RMEQ (Review Only), medical exam follow-up if deemed needed by PLHCP reviewer. Initial Only, unless there is change in health status or deemed needed by PLHCP.
Half/Full-Face negative pressure air purifying respirator,

Powered Air Purifying (PAPR)

Chemical, Pesticides,  Lead, etc…. Complete the RMEQ, medical exam follow-up if deemed needed by PLHCP reviewer. Spirometry Testing (ST) for User > Age 55, or others deemed needed by PLHCP. < Age 55 Annual Review of RMEQ only, unless deemed needed by PLHCP.  >Age 55, Annual RMEQ review, Examination, and ST.
Self-Contained Breathing Apparatus (SCBA) or Supplied Air Respirators Gas Cylinder Changing Complete the RMEQ, medical exam follow-up if deemed needed by PLHCP reviewer.and  medical exam. User Age >45 ST, <45 as deemed needed by PLHCP. <Age 45, Annual RMEQ review and medical exam, unless deemed not needed by PLHCP. > Age 45 Annual RMEQ review and medical exam with ST.
Self-Contained Breathing Apparatus (SCBA) or Supplied Air Respirators Spill Response Complete the RMEQ, and medical exam. User Age >45 ST, <45 as deemed needed by PLHCP. Annual RMEQ review and medical exam with ST as deemed needed by PLHCP.

Note: This medical requirement and frequency is for compliance with OSHA’s Respiratory Protection Standard only. There are different medical surveillance requirements and frequencies for employees who would come under other OSHA standards (silica, asbestos, lead, etc….).

Voluntary or comfort users of respirators form must submitted  before voluntary use is permitted while working at NC State.

All other respirator users, including required use of filtering facepiece (i.e. N-95), shall complete the Respirator Medical Evaluation Questionnaire (RMEQ). This is confidential medical information and the employee must complete this questionnaire without help from their supervisor. Their supervisor must not look at or review the answers on this form.

The respirator users shall also complete the Occupational Medicine Exam Request Form (RMEQ) and Authorization for Release of Medical Information Form. This form and RMEQ will then need to be submitted to NCSU Occupational Medicine or a local provider for review by PLHCP.

After the review of RMEQ by the PLHCP the respirator users will either be cleared for respirator use, or scheduled for a follow-up medical examination by the PLHCP.

The employee and supervisor will receive a copy of the PLHCP’s written recommendations called a health recommendation form (HRF), which will indicate whether or not they have been cleared to wear a respirator, and if there are limitations on such use. Information concerning diagnosis, test results, or other confidential medical information will not be disclosed to their employer by the PLHCP.

A powered air-purifying respirator (PAPR) must be provided to any employee if information from the PLHCP indicates that the employee can use a PAPR, but not a negative pressure respirator. If, subsequent to this evaluation, the PLHCP determines that the employee is able to wear a negative pressure respirator, the employer will no longer be required to provide a PAPR to that employee.

Additional medical evaluation or medical re-evaluation for any employee when:

  1. The employee reports medical signs or symptoms that are related to the employee’s ability to use a respirator.
  2. The PLHCP, supervisor, or the respirator program administrator observes that the employee is having a medical problem during fit testing or workplace respirator use.
  3. Information from the respiratory protection program, including observations made during fit testing and program evaluation, indicates a need for employee re-evaluation.
  4. A change occurs in workplace conditions (e.g., physical work effort, type of respirator used, protective clothing, and temperature) that may result in a substantial increase in the physiological burden placed on an employee.

Training and Fit Testing

Each employee required to wear a respirator must be trained prior to initial use.  For continued respirator use this training must be repeated at least every 12 months. The training must include at the least the following information:

  1. Why you need to use the respirator;
  2. What the respirator can and cannot do to protect you;
  3. How to properly inspect, put on and take off, and use your respirator;
  4. How to check the seal of your respirator (also called a “user seal check”);
  5. How to use the respirator effectively in emergency situations, including situations in which the respirator doesn’t work properly;
  6. How to recognize medical signs and symptoms that may limit or prevent you from using a respirator;
  7. How improper fit, usage, or maintenance can reduce your respirator ability to protect you;
  8. What the procedures are for maintenance and storage of the respirator; and
  9. What are the requirements for  OSHA’s Respiratory Protection Standards and NCSU Respiratory Protection Program.

The NCSU Environmental Health and Safety will offer either classroom or on-line general training on respirator use.

TrainingDescriptionCategoriesContact
Respirator Training - EHPS-OH100This training is intended for individuals who wear respiratory protection for work or research.   This training is a fundamentals level of information. Medical clearance and hands on training with fit testing are also required before wearing respiratory protection equipment.Occupational Health and Safety919-515-6862
Annual refresher training for Respirator use EHPS-OH101Annual Refresher training for Respirator UseOccupational Health and Safety919-515-6862

In addition to the general training, site specific training will need to be conducted by the site or departmental administrator. This training focuses on the specific practices and policies of the worksite and the employees’ responsibilities.

Fit-testing and fit-checks are important to ensure that there is a good seal between the face and respirator face piece. For respirators which require a tight seal, beard growth is not permitted. Fit testing will be required for all employees who are required to wear tight-fitting facepiece respirator and shall be performed:

  1. After an employee has completed their medical evaluation and prior to being allowed to wear any respirator with a tight fitting facepiece in the work environment.
  2. Whenever a different respirator facepiece is used.
  3. At least annually thereafter.
  4. When there are changes in the employee’s physical condition that could affect respiratory fit (e.g., obvious change in body weight, facial scarring, etc.).

Employees will be provided with several models and sizes of respirators so that they may find the optimal fit.  Environmental Health and Safety can provide fit testing as part of the hands on training.

For details on fit testing and fit-checks see the OSHA Fit Testing Video and Procedures.

Chemical Cartridge and Filter Change out Schedule

A Respirator Cartridge Change Schedule must be developed for cartridges or canisters used with air purifying respirators that do not have an End of Service Life Indicator (ESLI).  The purpose of this is to prevent contaminants from breaking through the respirator’s sorbent cartridge(s), and thereby over-exposing employees. A cartridge replacement schedule is followed based on manufacturer breakthrough test data and/or OSHA guidance. The following links provide direction on this issue:

Chemical cartridges should not be used for more than 6 hours in dry conditions and no more 4 hours in humid environments. Cartridges should not be left on respirators after each days use. Contact EHS for assistance on this issue and a table has been developed to document this schedule and should be included in the Work Site Specific Plan.

For respirators worn exclusively for protection against particles, filters will be changed according to the manufacturer’s specification and whenever the wearer detects an increase in breathing resistance.  It is the responsibility of the program administrator or area supervisor to ensure that the change schedule is complete and updated as necessary.

Inspection, Cleaning, Storage, & Maintenance

Respirators should be inspected before each use, after each use, and during cleaning and sanitizing. During your inspection, check the condition of the face piece, straps, valves, filter and/or cartridge elements, air hose and protective lens (full face or units with hoods). If parts are worn or defective, make certain that the unit is repaired or replaced. Be alert that not all respirators have replaceable parts. Respirator parts for different brands, (i.e Scott or 3M), are not interchangeable. If in doubt, contact  EHS.

Respirators, including Self Contained Breathing Apparatus (SCBA), maintained for emergency use, must be inspected monthly and after each use. Respirators that are maintained for use in emergencies will be certified by documenting the date that the inspection was performed, the name or signature of the inspector, the findings of the inspection, any required remedial action, and a serial number or other means of identifying the inspected respirator. This inspection shall follow the manufacturers’ instructions. This information can be provided on the written checklist.

Respirators will be cleaned and disinfected using the manufacturer’s recommendations for each respirator. The frequency of cleaning and disinfecting as follows:

  1. Respirators that are issued for the exclusive use of an employee will be cleaned and disinfected as often as necessary to be maintained in a sanitary condition. Employees will be responsible to clean and disinfect respirators issued for their exclusive use.
  2. Respirators used by more than one employee will be cleaned and disinfected prior to being used by a different individual.
  3. Respirators maintained for emergency use will be cleaned and disinfected after each use.

Store respirator to protect against dust, sunlight, extreme temperatures, physical damage, and moisture.  Use a separate bag to store filters and cartridges.  Storage location and instructions will be recorded in the Work Site specific plan.

All respirators are to be maintained according to manufacturer’s recommendations. Self-Contained Breathing Apparatus (SCBA) units require annual performance flow testing for the face piece and periodic overhauling by an authorized service representative. In addition SCBA Cylinders must undergo hydrostatic testing following the maker’s instructions, which is typically every 3-5 years at a minimum.

Breathing Air Quality

The Program Administrator will ensure that breathing air for atmosphere-supplying respirators will be of high purity, meets quality levels for content, and does not exceed certain contaminant levels and moisture requirements.

For supplied-air respirators (SARs), only Grade D breathing air shall be used in cylinders. The Program Administrator will coordinate deliveries of compressed air with the approved vendor and require certification that the air in the cylinders meets the specifications of Grade D breathing air. Moisture content in the cylinders will not exceed a dew point of –50° F (-45.6° C) at 1 atmosphere pressure. Note: This requirement will prevent respirator valves from freezing, which can occur when excess moisture accumulates on the valves. All breathing gas containers must be marked in accordance with the NIOSH respirator certification standard, 42 CFR part 84.

Compressors used for supplying breathing air must be constructed and situated so contaminated air cannot enter the air-supply system. The location of the air intake will be in an uncontaminated area where exhaust gases from nearby vehicles, the internal combustion engine that is powering the compressor itself (if applicable), or other exhaust contaminants being ventilated will not be picked up by the compressor air intake.

Compressors will be equipped with suitable in-line, air-purifying sorbent beds and filters to further ensure breathing air quality and to minimize moisture content so that the dew point at 1 atmosphere pressure is 10°F (5.56°C) below the ambient temperature. Sorbent beds and filters will be maintained and replaced or refurbished periodically according to the manufacturer’s recommendations.  An inspection tag will be kept at the compressor indicating the most recent change date and the signature of the Program Administrator or designee authorized to perform the maintenance. Only non-oil-lubricated compressors will be used.

The Program Administrator will ensure that the compressor intake will not allow the introduction of carbon monoxide greater than 10 parts per million (ppm) into the system.

Note: This could be from sources other than the compressor such as forklifts/vehicles or other gas powered equipment.

Breathing air couplings must be incompatible with outlets for non-respirable plant air or other gas systems to prevent accidental servicing of airline respirators with non-respirable gases or oxygen. No asphyxiating substance (e.g., nitrogen) will be allowed in the breathing airlines.

Record Keeping

The Program Administrator or supervisor will retain a copy of the PLHCP’s written recommendation for each employee subject to medical evaluation. Each employee’s completed medical questionnaire, results of relevant medical tests, examinations, and diagnosis, etc., will be maintained by the PHLCP for a period of 30 years. Records of medical evaluations will be made available as specified in 29 CFR 1910.1020, The Program Administrator or supervisor will retain fit test records for respirator users until the next fit test is administered.  These records consist of:

  1. Name or identification of the employee tested.
  2. Make, model, and size of the respirator fitted.
  3. Date of the fit test.
  4. Fit factor and other records of the test.

The Program Administrator or supervisor will retain employee training records that include the names of employees trained and the dates when training was conducted.

The Program Administrator will keep a current copy of the written respiratory protection program on file.  All written materials are required to be maintained under the recordkeeping requirements, and will be made available, upon request, to the employee who is subject to the records.

Program Evaluation

The Program Administrator is responsible to conduct evaluations of the workplace, as necessary. Periodic program evaluation is required to ensure that the provisions of the respiratory protection program are being implemented for all employees using respirators. In addition, evaluations will be conducted to ensure the continued effectiveness of the program. Evaluations of the workplace will determine whether the correct respirators are being used and worn properly and will also serve to determine whether the training program is effective. The program administrator and/or area supervisor is responsible to periodically monitor employee use of respirators to ensure that they are being used and worn properly.

The program administrator and/or area supervisor will regularly consult with employees wearing respirators to ascertain the employees’ views on program effectiveness and to identify any problems so that corrective action can be taken.

The following factors will be evaluated to determine program effectiveness:

  1. Respirators are properly fitted and if employees are able to wear respirators without interfering with effective workplace performance.
  2. Respirators are correctly selected for the hazards encountered.
  3. Respirators are used properly depending on the workplace conditions encountered.
  4. Respirators are being maintained and stored properly.

The Program Administrator will be responsible to correct any problems associated with wearing a respirator that are identified by employees or that are revealed during any other part of this evaluation.

Appendices