Did you know that respiratory protection was the fourth most cited OSHA violation? In 2014, there were 3,879 violations, ranking fourth for the seventh year in a row. The number one reason for receiving a citation from OSHA was the lack of a written respiratory program.With more than five million respirator users in approximately 1.3 million workplaces in the U.S., employers must be well versed in their responsibilities for providing the necessary resources to workers in order to promote safe and healthy work environments
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OSHA’s General Industry regulation 29 CFR 1910.134 obligates employers to: select the correct respirator when needed; provide medical evaluations; require fit testing and proper use; ensure proper care, maintenance and use; provide training and information. However, as mentioned above, the number one reason for an OSHA citation in 2014 was the employer failed to have a written respiratory program plan.
So when is a written respiratory protection plan needed?
- When engineering controls and work practices do not remove the inhalation hazards
- If the employee dons a respirator 30 or more days of the year
- If there is a probability that the employee might be exposed to a chemical substance above its permissible exposure limit
What are some the other reasons businesses got into trouble?
Below are two examples of OSHA inspections which resulted in serious violations.
In April OSHA issued a press release notifying it cited a ceramic mold manufacturing facility in Cudahy, Wisconsin for six violations with $50,050 in proposed penalties. Four were serious violations of the respiratory protection standards:
- Lack of medical evaluation for a worker required to wear a respirator
- Not conducting initial fit testing
- Not conducting annual fit testing,
- Allowing a respirator to be worn with a beard
In May, OSHA announced citations issued to an industrial cleaning firm in Wheeling, Illinois for these five serious violations:
- Failing to evaluate the respiratory hazards
- Failing to select appropriate respiratory protection based on the hazards
- Not Providing a written respiratory protection program
- Not training workers on the program
- Neglecting proper fit testing
Some of the respiratory protection citations OSHA hands out such as not even having a written program show, barring negligence, some businesses are not aware they need a Respiratory Protection Program or everything that is needed in one.
If you aren’t confident on both grounds, take a look at the following small business OSHA guidelines.
If your workplace meets one of these three tests, then in addition to the criteria mentioned earlier, the Respiratory Protection standard may apply.
A hazardous atmosphere, requiring a respirator has:
- Harmful levels of chemical, biological or radiological contaminants
- Known and reasonably foreseeable emergencies related to unknown exposure levels or exposures to substances without an OSHA PEL
- Insufficient oxygen
Elements of a Written Respiratory Protection Program
To ensure your respiratory protection program meets OSHA standards, make sure it includes all of these elements:
- Specific workplace
- Selecting respirators
- Medical evaluations of employees required to wear respirators
- Fit testing
- Routine and emergency respirator use
- Schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and maintaining respirators
- Ensuring adequate air quality for supplied-air respirators
- Training in respiratory hazards
- Training in proper use and maintenance of respirators
- Program evaluation
- Ensuring that employees who voluntarily wear respirators (excluding filtering facepieces) comply with the medical evaluation and cleaning, storing and maintenance requirements of the standard
- A designated program administrator who is qualified to administer the program
- Updating the written program as necessary to account for changes in the workplace affecting respirator use
- Providing equipment, training and medical evaluations at no cost to employee
- The most common air purifying respirators are the half-mask and the full-face with organic cartridges or canisters.
The following chart shows both organic and inorganic types of contaminants and their matching color coding.
Air Purifying Respirators Color Coding of Cartridges and Canisters