Avoiding Common Citations: A Written Respirator Policy and Program Will Ensure Proper Equipment Use

As the fall haul-out season begins, employers will most likely see a noticeable increase in requests for bottom painting, fiberglass work or gelcoat repair. As a result, this is a perfect time of year for employers to review and update the company’s respiratory protection policy. A good policy (and one that meets the regulatory requirements) will include a written policy, employee medical evaluations, and respirator fit testing. Proper recordkeeping is a critical and a necessary step to ensure compliance to the Occupational Safety and Health Administration (OSHA) standard.

Respirator Training
Many employers make the mistake of simply handing a new or existing employee a respirator and sending them off to work. However, under 29.CFR.1910.134, employers are required to complete many steps before allowing an employee to use a respirator. The first of these steps requires a written respirator policy (see 29.CFR.1901.1349(c)). The written policy becomes the foundation for training employees on proper respirator protocols. The written policy should detail the job functions that require respiratory protection. Safety Data Sheets often provide the needed information for employee personal protective equipment. However, as a guideline, an employee working with paints, epoxies, resins, strong solvents or hazardous dust will require a respirator.

The second step in the respirator program requires each employee to complete a medical evaluation (see 29.CFR.1910.134(e)). Since a respirator can reduce the amount of air entering the lungs, employees will need to be deemed medically cleared by a physician. Chronic pulmonary disorders such as asthma or emphysema may disqualify an employee. Other conditions, such as a history of cancer, smoking or previous injury to the lungs, may also disqualify an employee. The medical exam can be done by a local physician or by using an online service. After an initial clearance, the requirements for recertification become largely dependent upon an employee to self-report a medical issue. Although not required by OSHA, an annual medical evaluation is a simple, low-cost way to ensure the employee’s physical condition is suitable to wear a respirator. Consider an employee that smokes regularly, an annual medical evaluation may identify an issue with respect to that employee’s ability to wear a respirator.

Fit Testing
After the approved medical clearance has been provided, the third step in the respirator program requires employees to be fit tested. 29 CFR 1910.134(f) states, “Before an employee may be required to use any respirator with a negative or positive pressure tight-fitting facepiece, the employee must be fit tested with the same make, model, style and size of respirator that will be used.” So what is a fit test? A “fit test” tests the seal between the respirator’s facepiece and the employee’s face. It takes about 15 to 20 minutes to complete and is performed at least annually. After passing a fit test with a respirator, the employee must use the exact same make, model, style and size respirator on the job. Additionally, the standard requires employees to be fit tested on an annual basis. Also, the fit of the employee’s respirator must be retested whenever there is a change in the employee’s physical condition that could affect the fit of the employee’s respirator.

Such changes could include:
• large weight gain or loss;
• major dental work (such as new dentures);
• facial surgery that may have changed the shape of your face; or
• facial injury that results in significant scarring in the area of the seal.
Any of these changes could affect the ability of the employee’s respirator to properly seal to the employee’s face, which could allow contaminated air to leak into the employee’s respirator facepiece.

Common Respirator Citations
In addition to three steps listed above, other common OSHA citations related to respirators are often related to improper respirator storage and employees having facial hair that interferes with the seal. When not in use, respirators must be stored in a sealed container or bag. 29.CFR.1910.134(h)(2)(i)- All respirators shall be stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture and damaging chemicals, and they shall be packed or stored to prevent deformation of the facepiece and exhalation valve.

A common practice in the industry is to simply leave the respirator on a workbench or tool box at the end of the day. Overnight, airborne contaminants can settle into the respirator. As a result, employees can breathe in those contaminants when ‘masking up’ the next day or the next time respirator is used. Another violation involves facial hair in the seal area. Facial hair, like a beard or mustache, can affect the respirator’s ability to protect the employee. Anything that comes between the employee’s face and the respirator’s seal, or gets into the respirator’s valves, can allow contaminated air to leak into the respirator facepiece and the employee will not be protected.

Robert Smith is executive director of Fisher Phillips Safety Solutions, a firm specializing in workplace safety in marinas and boatyards. He can be reached by phone at 757-589-5391 or by email at rsmith@FPSafetySolutions.com.