Q. I’m the general manager of a metal finishing job shop. Several months ago, an employee requested a respirator for the addition of chemicals to several of our process tanks. Even though we have ventilation, we ordered a respirator through a safety catalogue. Since then, several other employees have requested dust masks when they are performing activities where dust is generated. I mentioned this to a friend of mine who works at a manufacturing plant. He asked if I had an OSHA program in place for respirators. I don’t know anything about this.
Could you provide me with an explanation of the OSHA requirements and how I need to go about implementing a program that meets the requirements and provides proper protections for our employees? J.W.T.
A. The respiratory protection standard (29 CFR 1910.134) has been around for quite some time. Many metal finishing applications need respiratory protection, including: vat chemical additions; operators stationed at process vats; wastewater treatment operators, grinding and polishing; spray painting; metal spray enclosures; grit blast rooms; process tank clean out; and solvent cleaning activities.
Here’s the process we recommend to develop your program: 1) Evaluate the plant, 2) Monitor industrial hygiene, 3) Create a written program, 4) Perform employee medical evaluations, 5) Perform employee fit testing and training, and 6) Evaluate the program annually.
For plant evaluation, review the material safety data sheets (MSDSs) of chemicals used onsite to determine potential risk. You need to use this information in conjunction with the method of application of these chemicals at your facility.
Tour your facility and evaluate areas where chemicals are being used. Airborne contaminants may or may not be easily identifiable, depending on particle size and physical state (i.e: solid, gas, mist).
Interview your employees. They may provide valuable insight on any personal conditions they have noticed from the use of certain chemicals.
From the review of MSDSs, application processes, and employee input, you should be able to determine areas of concern. At this point, you need to be able to quantify the exposure rate of employees and compare the results with OSHA’s permissible exposure limit (PEL), short-term exposure limits (STEL) and ceiling limits (C) as applicable. Most chemicals have a PEL, while the more hazardous chemicals have a STEL and/or ceiling limit. The exposure limits should be identified on the MSDS. If not, refer to OSHA Tables Z-1, Z-2, and Z-3 of the OSHA General Industry Air Contaminants Standard (29 CFR 1910.1000), which can be found at
osha.gov.
The second step is to conduct industrial hygiene monitoring, which is the process of measuring the exposure level of an employee. This typically involves attaching a small metering pump with tube and filter assembly on an employee for a portion of her shift in order to produce a time weighted average for an applicable period, such as 15 min or 8 hrs. Most facilities are not equipped to perform this type of monitoring and rely on an outside service provider. The service provider could be a local industrial hygiene firm or a service provided by the state. Many states’ Bureau of Worker Compensation programs offer this service at no additional cost, however, they typically limit the amount of monitoring they will perform, and you will need to be flexible and patient to get their service scheduled.
At the end of the sample period, the assembly is removed from the employee and the filter containing potential contaminants is sent to a lab for measurement. Once you know your process exposure rates in comparison with relevant standards, you can make a determination if the respiratory protection standard applies to your facility. Regardless of whether an applicable OSHA limit is exceeded or not, if your employees wear respiratory protection, other than a dust mask for comfort purposes, the standard applies, and you’re required to prepare a written respiratory protection plan.
There are many formats for a written program, but in the end, they need to contain a hazard evaluation; respirator selection; periodic medical evaluation—as defined by your health care provider; annual employee fit testing and training; respiratory maintenance and care; and an annual audit of the program.
In 2006, a major revision to the standard was finalized that requires the use of Assigned Protection Factors (APF) in making respirator selection. For example, if chemical “x” has an OSHA limit of 5 ppm, and a respirator from the APF table in the OSHA regulations (Table 1, 29CFR1910.134(a)(3)(i)(A)) has an APF of 10, then the maximum atmospheric concentration of TWA of chemical “x” for use of the respirator is 50 ppm (5×10). Therefore, if your test results for chemical “x” are more than 50 ppm, you will need to select a respirator with a higher APF until the product of the OSHA limit times the APF is less than the atmospheric test result.
After getting your written program in place, your employee must be evaluated and approved to wear such equipment. Wearing respiratory protection can place a physiological and possible psychological burden on the user. This evaluation must be performed by a physician or other licensed health care professional. Once the initial evaluation is performed, follow-up evaluation must be conducted on a periodic basis. After an employee passes the medical evaluation process, respirator fit testing and training is to be performed. Fit testing is only required for tight-fitting respirators. Make certain employees are fit tested using his/her respirator or one of the same make, model, size, and style. Your occupational injury/illness health care provider or your safety equipment supplier can typically perform this task. Fit testing and training related to use and care of the respirator must occur, at minimum, on an annual basis.
Lastly, a required part of your written program is the annual program evaluation of the workplace to make certain the written respiratory protection program is being properly implemented, and to consult employees to verify that they are using, cleaning, and storing the respirators properly. Items the annual evaluation must include are: respirator fit; appropriate respirator selection (if changes have occurred); and proper respirator use and maintenance.
OSHA standards are performance-based standards meaning there’s no particular way a program needs to be laid out, but it must include the above action items. If you determine that the respiratory protection standard does apply, then you will need to put it into a written plan for your facility. In addition to the OSHA regulations (osha.gov), there’s a Respiratory Protection e-tool that can help with clarification and program development, found at
osha.gov/SLTC/respiratoryprotection/index.html.
Another alternative is to evaluate your facility in order to determine if it is feasible through engineering or administrative controls so as to eliminate the need for respirators. OSHA general regulations require personnel protective equipment only if engineering and administrative controls are determined to be infeasible.
Hopefully, I’ve given you direction in establishing your respiratory protection program. Providing a safe workplace for your employees makes good business sense.
