Respiratory Protection – Voluntary Use?

1. Respiratory Protection – Voluntary Use? Presented by: Greg Boothe, MS, CIH, CSP EHS Services, LLC 113 Hazel Path, #4 Hendersonville, TN 37075 (615) 822-8902 gboothe@ehsservicesllc.com

2. Background • 1971 - OSHA adopted ANSI Z88.2-1969 and ANSI K13.1-1969 as its standard for respiratory protection. • April 1971 - OSHA promulgated 29 CFR 1926.103, the initial respiratory standard for the construction industry.

3. Background (cont.) • Feb. 9, 1979 - OSHA announced that 29 CFR 1910.134 would also apply to the construction industry. • Nov. 15, 1994 - OSHA issued a Notice of Proposed Rulemaking to revise 29 CFR 1910.134. • Jan. 8, 1998 - Final rule published.

4. 29 CFR 1910.134 • Adds a section of definitions • Filtering facepiece (dust mask) • Demand respirator • HEPA filter - N100, R100, P100 • Written respiratory protection program • More detailed requirements than old standard • Requires a program administrator • Requirements for voluntary use • Employer must pay for respirators, medical and training.

5. Written Program • Where respirator use is not required: • Employer may provide respirators or permit employees to use their own if it will not create a hazard in itself. • Employer must provide employees with the information contained in Appendix D. • Required elements of written program: • Medical • Cleaning, storage and maintenance procedures

6. Required Elements • In addition, the employer must establish and implement those elements of a written respiratory protection program necessary to ensure that any employee using a respirator voluntarily is medically able to use that respirator, and that the respirator is cleaned, stored, and maintained so that its use does not present a health hazard to the user. Exception: Employers are not required to include in a written respiratory protection program those employees whose only use of respirators involves the voluntary use of filtering facepieces (dust masks).

7. Written Program • Voluntary use (cont.) • Employees whose only use is the voluntary use of filtering facepiece respirators do not have to be included in the written respiratory protection program.

8. Appendix D • Appendix D to Sec. 1910.134 (Mandatory) Information for Employees Using Respirators When Not Required Under the StandardRespirators are an effective method of protection against designated hazards when properly selected and worn. Respirator use is encouraged, even when exposures are below the exposure limit, to provide an additional level of comfort and protection for workers. However, if a respirator is used improperly or not kept clean, the respirator itself can become a hazard to the worker. Sometimes, workers may wear respirators to avoid exposures to hazards, even if the amount of hazardous substance does not exceed the limits set by OSHA standards. If your employer provides respirators for your voluntary use, or if you provide your own respirator, you need to take certain precautions to be sure that the respirator itself does not present a hazard. You should do the following: 1. Read and heed all instructions provided by the manufacturer on use, maintenance, cleaning and care, and warnings regarding the respirators limitations. 2. Choose respirators certified for use to protect against the contaminant of concern. NIOSH, the National Institute for Occupational Safety and Health of the U.S. Department of Health and Human Services, certifies respirators. A label or statement of certification should appear on the respirator or respirator packaging. It will tell you what the respirator is designed for and how much it will protect you. 3. Do not wear your respirator into atmospheres containing contaminants for which your respirator is not designed to protect against. For example, a respirator designed to filter dust particles will not protect you against gases, vapors, or very small solid particles of fumes or smoke. 4. Keep track of your respirator so that you do not mistakenly use someone else's respirator.

9. Fit Testing • Required prior to mandatory use of a negative or positive pressure tight-fitting facepiece • Not required for voluntary use of respirator in non-hazardous environment

10. Respirator Use • Facepiece seal protection - tight-fitting respirator use is not allowed for facial hair that comes between the sealing surface and the face or that interferes with valve function when use is mandatory • Facial hair is allowed for voluntary use of respirators in non-hazardous environments

11. Training • Training required when the only use is voluntary • Employee must be presented with basic advisory information on respirators as presented in Appendix D • information may be presented in written or oral format but simply posting Appendix D is not acceptable

12. When Are Respirators Required? • When engineering and administrative controls are not enough! • Exposure exceeds a PEL • Specific standards requirements (e.g. asbestos work) • Exposure exceeds a TLV or REL if a PEL does not exist [5(a)1 citation] • Exposure exceeds an unsafe level the employer should know about [5(a)1] • Health effects present for chemicals with no OEL

13. Can Respirators be Required With no Overexposure? • Corporate Policy Requiring Respirators • Wording is important when exposures are below PELs or other recognized limits • Corporate IH requires – non voluntary • Corporate IH allows - voluntary OSHA Directive CPL 2-0.120

14. Filtering Facepiece and Medical Evaluation. • Voluntary use of filtering facepiece does not require written program or medical evaluation • Non-voluntary use of filtering facepiece requires written program and medical evaluation.