Page 19 - Occupational Health & Safety, February 2017

cluding disposable dust masks. Along with the equipment, employers must establish and implement a written res- pirator program and specific workplace procedures. As seen in column one of the OSHA Regulations Section 1910.134 Summary Sheet, all program require- ments apply except Appendix D.
■ Voluntary Use: Consists of a filter- ing facepiece, such as a disposable dust filtering facepiece respirator. In this case, only certain elements of the respiratory protection program are required to be es- tablished. The employer must ensure a qualified program administrator is desig- nated, the employee is medically able to use that respirator, and the respirator is cleaned, stored, and maintained so that its use does not present a health hazard to the user. Lastly, the employer must provide em- ployees with Appendix D. This can be seen in column three of the OSHA Regulations Section 1910.134 Summary Sheet.
■ Voluntary Use of a Respirator More than a Disposable Dust Mask: Consists of a respirator other than that of a filtering facepiece, such as half masks or full face cartridge respirators. In this case, Appendix D still applies, but other specific program requirements listed in column two of the OSHA Regulations Section 1910.134 Summary Sheet apply. This in- cludes medical evaluations, designating a program administer, and developing pro- cedures for cleaning and repairing respira- tory equipment.
Respiratory Protection Program
In OSHA’s list of 2016 Top Violations, respi- ratory protection ranked No. 4 with a total of 3,573 violations cited. The top 5 sections cited were:
1. 1910.134(e)(1) Medical evaluation for respiratory protection: 615 violations
2. 1910.134(c)(1) Respiratory protec- tion requirement: 499
3. 1910.134(f )(2) Respirator fit testing: 341
4. 1910.134(c)(2)(i) Employer must es- tablish respiratory program: 241
5. 1910.134(d)(1)(iii) The employer shall identify and evaluate the respiratory hazard(s) in the workplace: 235
It’s more important than ever for em- ployers to stay focused on OSHA regu- lations—not only to avoid citations and costly fines, but also to protect the organi-
zation’s most valuable asset, its employees. When mandatory or voluntary respirators are being used, an appropriate written re- spiratory protection program must be in place. This avoids the “grab and go” men- tality and ensures the health and wellness of workers. A respirator program must include work site-specific procedures that address the following:
■ Proper respirator selection
■ Medical evaluations of employees required to use respirators
■ Fit testing procedures for tight-fit- ting respirators
■ Procedures for proper use of respi- rators in routine and reasonably foresee- able emergency situations
■ Procedures and schedules for clean- ing, disinfecting, storing, inspecting, re- pairing, discarding, and otherwise main- taining respirators
■ Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators
■ Training employees in the respira- tory hazards to which they are potentially exposed during routine and emergency situations
■ Training employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance
■ Procedures for regularly evaluating the effectiveness of the program.
All of these must be addressed for man- datory and emergency respiratory use.
Training Requirements
Understanding why, when, and how to use a respirator is more complicated than oper- ating the respirator itself. Training helps to eliminate improperly worn, poorly main- tained, or nonfunctional equipment that leads to a false sense of security, which can be worse than no protection at all. OSHA’s training provisions require the employer to ensure that each employee can demon- strate knowledge of at least the following:
■ Why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator
■ What the limitations and capabili- ties of the respirator are
■ How to use the respirator effectively in emergency situations, including situa- tions in which the respirator malfunctions
■ How to inspect, put on and remove, use, and check the seals of the respirator
■ What the procedures are for mainte- nance and storage of the respirator
■ How to recognize medical signs and symptoms that may limit or prevent the ef- fective use of respirators
■ The general requirements of the re- spiratory protection regulation.
Training must be conducted prior to respirator use. Retraining is required an- nually, whenever changes in the workplace or type of respirator would make previous training obsolete, when there are indica- tions that the employee’s knowledge is inadequate, and under any other circum- stances where retraining would be neces- sary to ensure safe respirator use. The only exception is the voluntary use of filtering facepiece respirators (dust masks). As pre- viously stated, those individuals need only to be provided with Appendix D. When reviewing this with employees, it is recom- mended that two copies of Appendix D are given to each employee. The employees keep one copy and the other copy they sign, acknowledging it was reviewed with them, and management keeps this record for fu- ture reference.
Conclusion
Make workers think twice the next time they pick up and use a respirator in the workplace. Eliminate the “grab and go” mentality by educating workers on the dif- ference between mandatory and voluntary respiratory use, take the time to develop a respirator protection program, and provide effective respirator trainings. Results will include protecting the organization’s most valuable asset, its employees.
Steve Adamavich (sadamavich@fehr- graham.com) is a Project Manager at Fehr Graham in Plymouth, Wis. He is a UW-Whitewater graduate with more than 20 years of health and safety experience, with a background that includes both hu- man resources and occupational safety. He has performed detailed audits at facilities throughout the United States and abroad; his experience also includes the development and implementation of safety programs for various manufacturing facilities, conducting safety trainings, and supervision of opera- tions to ensure compliance with all aspects of safety regulations.
www.ohsonline.com
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