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 cant 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.)
WHY WEAR RESPIRATORS?
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
WHEN TO WEAR THEM
Working conditions under which respirators are most often used involve
Confined or enclosed spaces;
Oxygen-deficient atmosphere (less than 19.5 percent oxygen at sea
Atmospheres with potentially high concentrations of toxic gases, vapors
Atmospheres immediately dangerous to life and health (IDLH);
WHICH TO WEAR?
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
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
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
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
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
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 OSHAs 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
employees 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 workers fitness to wear
a respirator, the medical professional must be given a copy of the employers 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
employees 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)