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UE News, April and May 1998

Under a new OSHA standard which went into effect April 8, employers must develop a written, comprehensive respiratory protection program for all workers who are required to use respirators on the job.

These written programs must include company procedures for:

  • Selecting and maintaining respirators.

  • Fit-testing the respirators;

  • Training workers on the airborne hazards they face;

  • Training workers on the proper use and maintenance of respirators; and

  • Medical evaluations for respirator use.

This standard (CFR 1910.134, "Respiratory Protection") also requires, for the first time, that employers provide respirators under working conditions that are immediately dangerous to life and health, and specifies which types of respirators must be used in these situations. Many other respirator requirements are spelled out in the new standard.

An estimated five million workers in 1.3 million U.S. workplaces are covered by the new standard. OSHA expects that compliance with the standard will reduce worker exposure to airborne toxic hazards by 27 percent on average. The standard will prevent "hundreds of deaths and thousands of illnesses," OSHA estimates.

OSHA also believes that three-quarters of the U.S. companies which require respirators on the job are not now in compliance with the new standard. While the new regulations went into effect on April 8, employers still have until Sept. 8, 1998 to determine whether or not respirators must be used in their plants, and until Oct. 5, 1998 to comply with all provisions of the standard. But for firms which already use respirators, compliance has been required for the past few weeks.

With so many firms now out of compliance, unionized workers will have to see to it that proper respiratory protection and procedures are put into place promptly. (We can’t wait for OSHA inspectors to do this — they may not get around to our shops for another 25 years or so according to current federal enforcement statistics.)


Respirators prevent harmful substances in the air from entering our bodies when we breathe, and if necessary provide an adequate supply of clean air for breathing. The best way to protect workers from atmospheric hazards is by the use of engineering controls, such as proper ventilation, enclosure of hazardous operations and/or substitution of less toxic materials. If engineering controls have been tried and failed to do the job, OSHA requires that respiratory protection be used. Respiratory protection may also properly be used temporarily while control measures are being put in place.

Respirators are inconvenient to wear, and often make breathing difficult. As OSHA has stated, "Respirators have their limitations and are not a substitute for effective engineering controls. Where respirators are necessary for health protection, specific procedures are necessary to overcome potential deficiencies and to assure effectiveness."


Working conditions under which respirators are most often used involve work in:

  • Confined or enclosed spaces;

  • Oxygen-deficient atmosphere (less than 19.5 percent oxygen at sea level);

  • Atmospheres with potentially high concentrations of toxic gases, vapors or dusts;

  • Atmospheres immediately dangerous to life and health (IDLH);

  • Firefighting.


When the occasion requires respirators, which kind should be used? There are many to choose from, and NIOSH and OSHA have detailed technical guides for selecting the appropriate ones.

But in general there are two basic classes of respirators: air-supplying and air-purifying.

Most often industries use air-purifying respirators. These may be, for example, ordinary common double-cartridge respirators. They can be as simple (and often as ineffective) as a cheap plastic face mask, or as complex as a Powered Air-Purifying Respirator (also known as a PAPR). While relatively comfortable and lightweight, air-purifying respirators have many serious limitations:

  • They should never be used under IDLH conditions or in oxygen-deficient atmospheres;

  • They only protect against specific chemicals and only up to certain concentrations in the workroom air;

  • They only protect for a limited period of time. In most cases (unless the respirator has an end-of-service-life indicator) it is difficult to know when cartridge life has ended, and thus when effective protection has ceased. As a result, air-purifying respirators should only be used with gases and vapors which have adequate warning properties, such as a noticeable odor and/or cause mild eye, nose or throat irritation.

When oxygen levels may be dangerously low, as during a fire or in an enclosed space, air-supplying respirators should be used. Most often this equipment will be a Self-Contained Breathing Apparatus (called an SCBA or "Scuba"). These are bulky and heavy (often about 35 pounds) and make it difficult to get in and out of confined spaces. SCBAs are often designed to provide about 30 minutes of air for breathing, but may only last for 10 or 15 minutes under strenuous work conditions, such as firefighting.


Employers who require respirators to be used on the job are now required to give annual training on respirator use. The training must be "comprehensive" and "understandable." (This latter requirement is important in plants where English is not the first language of many workers.) Respirator training must cover:

  • Why the respirator is necessary

  • What protection the respirator can give if properly fit and maintained

  • The limitations of the respirator

  • How to inspect, put on and remove and use the respirator, and check its seals

  • How to use the respirator in emergencies, including conditions in which the respirator malfunctions

  • How to recognize medical signs and symptoms that may prevent or limit effective use of the respirator

  • The general requirements of OSHA’s respirator protection standard.

Retraining must be given at least annually, or when changes in the workplace or in the type of respirator used makes previous training obsolete. New or transferred employees must be given their respirator training before being required to use the respirator.

(Note: If companies with respirator programs in place before April 8, 1998 can show that they have provided such training within the past 12 months, they do not have to begin the training outlined above until 12 months after they last provided it. If they did not provide such training within the last 12 months before April 8, and have not yet done so, they are currently in violation of these OSHA regulations.)


Because the use of respirators can place a burden on the body and aggravate some medical conditions, medical exams are required before a worker is fit-tested and told to wear a respirator. Of special concern is the health of workers who suffer from heart disease or respirator problems.

The medical evaluation consists of a written questionnaire, and a medical exam conducted by a physician or a licensed health care professional. The medical questionnaire and exam must be administered "confidentially during the employee’s normal working hours or at a time and place convenient to the employee." Also, the employer must provide each worker the opportunity to discuss his or her questionnaire or exam results with the doctor or health professional.

Before making any medical determination of a worker’s fitness to wear a respirator, the medical professional must be given a copy of the employer’s written respiratory protection plan, as well as information about the type and weight of the respirator to be used, the expected frequency of use, and the working conditions under which it will be used.

The professional must make a written recommendation about each employee’s fitness to use their designated respirator, and a copy of this must be given to the employee. The recommendation can only relate to medical aspects of respirator use and the need for follow-up exams, if any. It cannot, by law, provide any other information or diagnosis made by the physician or licensed professional except as it relates to fitness to wear a respirator. In other words, this exam cannot be a medical fishing expedition on behalf of your employer.

Common air-purifying respirators, such as half-face and full-face cartridge respirators, can sometimes place an undue health burden on employees with heart or respiratory conditions. Positive-pressure respirators, such as PAPRs (powered air-purifying respirators), do not place so great a burden on these workers, and often can be worn safely when cartridge respirators are not appropriate. If the medical professional finds that an employee cannot wear a cartridge respirator, but can wear a PAPR, then the employer must provide a PAPR to that employee, according to the new regulations.

(This article was originally published in two parts: in the April and May, 1998 issues of the UE News)

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