MRO Today - Respirators: Don't hold your breath

Don't hold your breath
Make sure your respiratory protection program
complies with OSHA's revised standard

by Ingemar H. Olsson

The Occupational Safety and Health Administration’s revised 29 CFR 1910.134 regulation is among the more recent and significant changes affecting respiratory personal protective equipment (PPE).

In contrast to the equally significant National Institute of Occupational Safety and Health 42 CFR Part 84 standard that regulates respirator manufacturers, 29 CFR 1910.134 applies to companies in general industry, construction, shipyard, longshoring and marine terminal workplaces.

Compliance checklist
Use the following checklist to ensure your written respiratory protection program complies with the revised 29 CFR 1910.134:

Written program: This simply means documenting the company’s standard operating procedures governing the selection and use of respirators in both routine and emergency situations. The need for a program administrator is new for OSHA respirator regulations. Designate a person to oversee and direct any program and evaluate its effectiveness.

Respiratory selection: Many factors are involved in selecting the proper respiratory protection — the nature of the application (work environment), the chemical or chemicals in question and exposure concentrations.

Training: This must occur before a respirator is used in a work environment. Companies must train annually and more frequently under certain circumstances. Respirator fit testing is a key addition and an important part of the training process since a respirator that does not fit well or comfortably won’t provide the intended protection. Do this as part of the initial training process and follow up on a regular basis, or as conditions change.

Cleaning and disinfection: The standard states “respirators shall be regularly cleaned and disinfected. Those used by more than one worker shall be thoroughly cleaned and disinfected after each use.”

Inspection and repair: Inspect respirators for defects. OSHA requires that “all respirators be inspected routinely before and after each use,” with the exception of those used as emergency escape and rescue devices. These “shall be inspected after each use and at least monthly.” The standard also requires that companies define both routine and emergency uses.

Storage: Proper storage helps ensure that any respirator will function as designed. After cleaning, inspection and repair, store respirators in a clean, dry place.

Work area surveillance: Briefly, this requires air sampling to identify contaminants and concentrations. Respirators cannot be properly chosen without this data.

Program effectiveness: Modify your respirator program as changes in respiratory protection needs arise.

Medical evaluation: Don’t assign a respirator-requiring task to anyone unless he or she is physically able to perform the work and use the equipment.

In effect since October 1998, 29 CFR 1910.134 requires that in any workplace where respirators are necessary to protect worker health, or where the company requires them, the company must implement a written respiratory protection program with worksite-specific procedures.

Even though you are already following your respirator manufacturer’s instructions and/or have a comprehensive written program in place, it’s a good idea to frequently review your procedures and remain in compliance.

Here are some key provisions of 29 CFR 1910.134:

-- Companies must attempt to use engineering controls to protect workers from air contaminants. Respirators are a last resort.

-- Where required, companies must supply respirators.

-- Companies must designate a program administrator.

-- Companies must have and follow a written program containing procedures for:
1) selecting respirators,
2) medical evaluations of respirator wearers,
3) fit testing,
4) using respirators in routine and reasonably foreseeable emergency situations,
5) respirator cleaning and maintenance,
6) ensuring adequate air quality and flow of breathing for atmosphere-supplied respirators, and
7) training and evaluation programs for effectiveness.

Chemical cartridge criteria
Perhaps the most dramatic aspect of the revised OSHA standard is its criteria for using chemical cartridge respirators. It gives companies three options when they need cartridges or canister for gases and/or vapors.

OSHA’s first choice is use of a supplied-air respirator. If that is not feasible, use a cartridge or canister with an NIOSH-approved End of Service Life Indicator (ESLI). If that is not available, implement a cartridge changeout schedule.

You must implement cartridge changeout schedules into the company’s Written Respiratory Protection Program under 1910.134(d), which covers procedures for selecting respirators; 1910.134(g), covering proper use; and 1910.134(k), covering training.

Why the change? OSHA believes chemical cartridge respirator wearers often become overexposed due to the wearer’s inability to detect cartridge breakthrough.

In the previous regulation, cartridges were OK as long as certain parameters — spelled out on the NIOSH approval label — were met. These included the use of cartridges against contaminants with good warning properties only. Any contaminant with unknown or poor warning properties negated the use of cartridges and required supplied-air respirators.

Even though many contaminants have documented odor thresholds well below the permissible exposure limit (PEL), OSHA believes many workers do not rely on this olfactory warning, or cannot detect it at all because of previous overexposure.

Gone, however, are the days when one simply relied on taste or smell to detect cartridge breakthrough. The revised standard doesn’t permit this.

The purpose of the standard’s cartridge changeout schedule is to have the respirator wearer replace the chemical cartridge or canister before breakthrough, instead of relying on the contaminant’s warning properties.

All chemical cartridges have a definite service time based on many factors, such as contaminant concentration, humidity, temperature and the worker’s breathing rate. After the cartridge absorbs the particular contaminant to its capacity, the contaminant begins to pass through the cartridge and enter the facepiece. This “breakthrough” is the cartridge’s service life.

According to OSHA, cartridge replacement shouldn’t be dictated by the wearer’s ability to detect breakthrough, but rather by a specific time period that the cartridge or canister is used.

It’s important to note that cartridges can only be used against contaminants with good warning properties. A changeout schedule does not allow using cartridges against contaminants with unknown or poor warning properties. It’s vital that the wearer be able to detect the contaminant at a safe level (below the PEL) in the event of respirator malfunction or inadequate fit as a result of facepiece slippage.

Respirator manufacturers have CD-ROMs and other software available to help employers develop changeout schedules.

Ingemar H. Olsson is a national sales manager for Dalloz Safety, a manufacturer of personal protective equipment.

For more info about OSHA’s revised respirator standard, visit www.osha.gov. For info on NIOSH’s standard, visit www.cdc.gov/niosh/homepage.html.

This article appeared in the October/November 1999 issue of MRO Today magazine. Copyright, 1999.