Compliance Perspectives: How to Implement a Respiratory Protection Program at Your Lab

Worker exposure to infection and hazardous substances is a constant and pressing challenge for lab managers. And if yours is among the many labs where workers are required to use respirators, you face the additional challenge of complying with the OSHA Respiratory Protection Standard (Section 1910.134). The centerpiece of the Standard—and primary source of OSHA respiratory protection citations—is the mandatory implementation of a Respiratory Protection Program (RPP). Here’s a look at RPP requirements and the 10 things your own Program must include.

OSHA REQUIREMENTS

Does Your Lab Need an RPP?
One of the hardest parts about keeping lab workers safe and healthy is preventing them from breathing in the substances that can poison them. The ideal solution is to use engineering controls like ventilating systems to eliminate airborne hazards or at least reduce them so that workers’ exposure is kept below the permissible exposure limit (PEL) for the particular substance. But where use of engineering controls isn’t reasonably practicable, labs must require respirator use to keep workers’ exposure below the PEL.

The OSHA Occupational Exposure to Hazardous Chemicals in Laboratories Standard (Section 1910.1450(i)) stipulates that in this situation where respirator use is required, the lab must furnish and pay for the necessary equipment and follow the OSHA Respiratory Protection Standard, including the requirement to implement a written RPP run by a “suitably trained program administrator” that sets out specific safety measures for respirator use in the workplace (Sec. 1910.134(c)).

10 Elements to Include in Your RPP

1. Respirator Selection

There are many different types of respirators, each of which has its own specific capabilities and limitations. The RPP must set out your procedures and criteria for selecting the appropriate respirator. Respirators must be NIOSH-certified and meet Standard requirements. There are two sets of respirator selection criteria—

• One for use in atmospheres that are IDLH (immediately dangerous to life or health); and
• Another for non-IDLH atmospheres.

2. Medical Evaluation of Prospective Respirator Users

Lab workers required to use respirators must undergo medical testing by a doctor or other licensed health care professional before they’re fit tested and use the respirator for the first time. Stage 1 of medical evaluation is a baseline exam in which the worker fills out an OSHA questionnaire or provides equivalent information. Follow-up testing is required for workers that report medical conditions that could make respirator use dangerous. Re-evaluation is required if users show certain symptoms or after changes in work conditions affecting respirator use.

3. Fit Testing of Tight-Fitting Respirators

The RPP must provide for mandatory fit testing of workers required to use respirators that include a tight-fitting facepiece to ensure a proper fit and prevent leakage. Fit testing must be done before first use and at least once a year thereafter. The two test methods you can use:

• Quantitative Fit Testing, which uses a numerical measure to assess fit; and
• Qualitative Fit Testing, which involves a pass/fail test.

4. Respirator Use Procedures

The RPP must include procedures for proper use of respirators in both routine and emergency situations, including procedures to:

• Prevent leaks in the respirator facepiece seal;
• Prevent workers from removing respirators in hazardous environments;
• Ensure that respirators operate effectively throughout the work shift;
• Protect workers entering IDLH atmospheres; and
• Protect workers engaged in structural firefighting.

5. Respirator Cleaning, Maintenance & Repair Procedures

You must furnish respirator users equipment that’s clean, sanitary and in good working order. The RPP must incorporate a system for ensuring proper care and maintenance of respiratory equipment, including procedures for proper:

• Cleaning and disinfecting;
• Storage;
• Inspection; and
• Removal or repair of defective equipment.

6. Atmosphere-Supplying Respirator Breathing Air Requirements

If you require workers to use atmosphere-supplying respirators that provide breathing air from an independent source so that the user doesn’t breathe the air in the work area (supplied-air respirators (SARs) or self-contained breathing apparatus (SCBA)) you must take measures to ensure that the breathing air supplied is safe, including ensuring:

• Breathing air meets quality standards;
• Oxygen use restrictions are in place to limit fire and explosion risks;
• Measures are in place to ensure safe use of cylinders, compressors and couplings; and
• Breathing gas containers are appropriately labeled.

7. NIOSH Labeling of Filters, Cartridges & Canisters

Your RPP must require all respirator filters, cartridges and canisters to have a proper NIOSH label and color coding and ban anybody from removing, defacing, obscuring or doing anything else that makes the label illegible.

8. Respirator Safety Training

The RPP must ensure that all workers required to use a respirator receive the proper training before first use. The Standard doesn’t prescribe any particular training program but does list specific things workers must be able to “demonstrate knowledge” of before you can consider their training complete. It also explains when and how training must be provided.

9. Ongoing Program Evaluation

You must periodically monitor your RPP to evaluate its effectiveness. Monitoring involves consulting with workers required to wear respirators to get their feedback on how respirators are working, identifying problems and taking corrective actions.

10. Recordkeeping

Finally, you must retain and make available to workers, their representatives and OSHA officials upon request for inspection and copying certain RPP related records, including:

• A copy of the RPP itself;
• Medical evaluation records; and
• Respirator fit testing records.