The Occupational Safety and Health Administration (OSHA) requires employers to evaluate whether air quality in their workplaces requires respiratory protection for workers, and to establish comprehensive evaluation and respiratory protection programs where necessary. In September, OSHA issued minor revisions to its respiratory protection requirements provisions for general industry (29 CFR 1910.134), adding two new quantitative fit testing protocols. Because of these changes, now is a good time for employers to review requirements and compliance programs.
What Does the Respiratory Protection Standard Require?
The Respiratory Protection Standard requires employers to ensure that workplace air is safe for employees to breathe. Potential contaminants might be chemical or biological, and might appear as harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors. The Standard does not specify contaminants to test for, nor the tests to use – although readers should remember that OSHA’s Airborne Contaminant Standard addresses hundreds of common contaminants.
- What hierarchy of protection applies?
The Standard establishes a two-step order of preferences for employers to follow:
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First, employers are to prevent potential contamination through appropriate design measures and engineering controls. If these are completely successful, then the detailed provisions set forth below do not apply. “Feasible” engineering control measures may include enclosure or confinement of operations, general and/or local ventilation, and substitution of less noxious materials.
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Second, however, where it is not feasible to prevent contamination, then the employer must develop and implement a Respiratory Protection Program to provide each affected employee with appropriate personal protection equipment (PPE), including a respirator, and to train each employee how to use and maintain the PPE.
- What detailed requirements apply when a Respiratory Protection Program is necessary?
When a Respiratory Protection Program is required, it must contain the following elements, which OSHA’s Standard prescribes in detail:
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Designated Respiratory Protection Program administrator
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Procedures for selecting appropriate respirators suited to identified hazards
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Medical evaluations to ensure that employees required to use respirators can do so safely
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Fit testing protocols (including qualitative fit test (QLFT) and quantitative fit test (QNFT) protocols) and procedures (see below)
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Procedures for proper respirator use in routine and reasonably foreseeable emergency situations
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Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators
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Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators
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Proper labeling and color coding of respirator filters, cartridges, and canisters
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Training of employees in the respiratory hazards to which they are exposed and in proper respirator use
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Procedures for regularly evaluating the effectiveness of the program
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Record-keeping provisions.
What Changes has OSHA Just Adopted?
OSHA has added two additional quantitative fit test protocols, effective September 26, 2019. These protocols are:
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The modified ambient aerosol condensation nuclei counter (CNC) quantitative fit testing protocol for full-facepiece and half-mask elastomeric respirators; and
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The modified ambient aerosol CNC quantitative fit testing protocol for filtering facepiece respirators.
Both are abbreviated variations of the original OSHA-approved ambient aerosol CNC quantitative fit testing protocol (often referred to as the PortaCount® protocol), which provide differing exercise sets, exercise duration, and sampling sequences. They provide alternatives to the four previously approved quantitative protocols.
Self-Assessment Checklist
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Has the organization evaluated its workplaces to identify possible air contamination that can be hazardous to workers?
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If so, which contaminants have been evaluated, and which testing methods were applied?
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Has the organization identified any workplaces that do present workplace air contamination hazards?
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If so, has the organization eliminated these hazards in all such workplaces?
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If any workplaces contain air hazards that cannot feasibly be eliminated, has the organization implemented respiratory protection programs, compliant with OSHA requirements, covering all affected employees?
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If so, do any programs include quantitative fit testing for respirators that may be eligible for OSHA’s newly-approved protocols?
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Where Can I Go For More Information?
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OSHA Respiratory Protection web portal
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Respiratory Protection Standard (29 CFR 1910.134)
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September 26, 2019 revisions (Federal Register)
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The National Institute for Occupational Safety and Health (NIOSH) respirators website.
Specialty Technical Publishers (STP) provides a variety of single-law and multi-law services, intended to facilitate clients’ understanding of and compliance with requirements.
About the Author
Jon Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 30 years.
Mr. Elliott has a diverse educational background. In addition to his Juris Doctor (University of California, Boalt Hall School of Law, 1981), he holds a Master of Public Policy (Goldman School of Public Policy [GSPP], UC Berkeley, 1980), and a Bachelor of Science in Mechanical Engineering (Princeton University, 1977).
Mr. Elliott is active in professional and community organizations. In addition, he is a past chairman of the Board of Directors of the GSPP Alumni Association, and past member of the Executive Committee of the State Bar of California's Environmental Law Section (including past chair of its Legislative Committee).
You may contact Mr. Elliott directly at: tei@ix.netcom.com