Respirator program evaluation

Safety officials must ensure that their organization s respiratory protection program complies with the elements covered in the sample program presented above, and they must also ensure that respirator program evaluations are also accomplished. Why Because 29 CFR 1910.134 requires regular inspection and evaluation of the respirator program to determine its continued effectiveness in protecting employees. Remember that periodic... 

Sample Respiratory Protection Evaluation Checklist Respirator Program Evaluation Checklist... 

The employer is required to address in its written program the type of regular surveillance of the workplace necessary to evaluate the effectiveness of the respirator program. Other items discussed in the standard include ... 

Program evaluation. This section requires the employer to conduct evaluations of the workplace to ensure that the written respiratory protection program is being properly implemented, and to consult employees to ensure that they are using the respirators properly. 

A periodic program evaluation to ensiire that respirator use continues to be effective. 

Program evaluation includes discussions with employees required to use respirators to assess the employees views on program effectiveness and to identify any problems. Any problems that are identified during this assessment must be corrected. Factors to be assessed include, but are not limited to... 

The company needs to retain written information regarding medical evaluations, fit testing, and the respirator program. This information will facilitate employee involvement in the respirator program, assist the company in auditing the adequacy of the program, and provide a record for compliance determinations by OSHA. 

A physician, supervisor, or the respirator program administrator should inform the company that an employee needs to be re-evaluated. 

In general, the respirator program should be evaluated for each job at least annually, with program adjustments made as appropriate to reflect the evaluation results. Program function can be separated into administration and operation. 

Identification of respirator-related medical conditions (e.g., skin irritation) should be part of the program evaluation. Employees identified during the evaluation as having skin irritation can either be referred to the PLHCP or be advised by the program administrator about the need to leave the respirator use area as necessary to wash the face and face piece, as permitted under the standard. It should be noted that paragraph (e)(7)(iii) of the standard requires medical evaluation if observations made during the program evaluation indicate that such evaluation is necessary. 

Also, operations where dust masks are used need to be evaluated and the results of the evaluation should be included with the documentation for the respirator program to show the dust masks are adequate for the task. 

Program Evaluation. An annual evaluation should be conducted to determine whether respirators are being correctly used, maintained, and stored. This evaluation should include physically inspecting a representative sample of the respirators used on the site. The representative sample should include at least 10% of the respirators used on site. 

Written standard operating procedures Program evaluation procedures Respirator selection procedures Training program... 

This program requires that an employer provide an employee working in an environment with a respiratory hazard all of the following (1) a respirator, (2) training in use and maintenance of the respirator, and (3) medical evaluations as deemed necessary at no cost to the employee. 

Where the use of respiratory protection is indicated, then the OSHA standard for respiratory protection in 29 CFR 1910.134(c) includes the statements (1) In any worlq)lace where respirators are necessary to protect the health of the employee, the employer shall establish and implement a written respiratory protection program with work site specific procedures.. .. The employer shall include in the program the following provisions...(ii) Medical evaluations of employees required to use respirators and in 29CFR 1910.134(e) is the following ... 

Engineering and work-practice controls must be implemented whenever employees are exposed above the PEL for more than 30 days per year. The controls include the requirement for a written compliance program to reduce personal exposures to below the PEL. If engineering and work-practice controls do not reduce exposures to below the PEL, respirators must be worn. If mechanical ventilation is used to control exposures, the ventilation system must be evaluated quarterly for its effectiveness in controlhng exposures (29 CFR 1910.1025(e)). 

The employer will ensure that an annual inspection/evaluation of the program is conducted to determine the continued effectiveness of the program. The RPA will make frequent inspections of all areas where respirators are used to ensure compliance with the respiratory protection requirements. 

Keep in mind that this Toolbox Talk covers the voluntary use of dust masks only. It does not cover the voluntary use of other respirators, such as elastomeric air-purifying respirators or powered air-purifying respirators. In those cases, there are further provisions for you to follow at 1910.134, such as for medical evaluation, scheduling, and certain elements of a written program. Also, this Toolbox Talk does not cover surgical masks, which are not considered respirators nor dust masks. Finally, if dust masks are required to be used by the employer, even when not required by OSHA, they cannot be considered Voluntary use. ... 

A suitably trained program administrator must administer the respiratory program. Employers are not required to include in the written program employees whose only use of respirators involves the voluntary use of dust masks. The employer s responsibilities include providing respirators, training, and medical evaluations at no cost to the employee. 

In addition to respirator selection, a complete written respiratory protection program should be instituted which includes regular training, maintenance, inspection, cleaning, and evaluation. If you can smell MC while wearing a respirator, proceed immediately to fresh air. If you experience difficulty in breathing while wearing a respirator, tell your employer. 

All new and regular employees who fill job classifications that require respirator use in the performance of their duties are required to pass an initial medical examination to determine fitness to wear respiratory protection on the job. Annual spirometric evaluations will be conducted to ensure that employees covered under this program meet the OSHA requirements for fitness to wear respirators. On a continuous 5-year basis, all company employees covered under this program will be reexamined by competent medical authorities to ensure their continued fitness to wear respiratory protection on the job. 

The discussion does not need to focus on all the details of the standard but could, for example, simply inform employees that employers are obligated to develop a written program, properly select respirators evaluate respirator use correct deficiencies in respirator use conduct medical evaluations provide for the maintenance, storage, and cleaning of respirators and retain and provide access to specific records. 

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