Respiratory Protection

Introduction

The purpose of this policy is to define the basic elements and responsibilities to ensure the safe use of respiratory protection.

Scope

This standard shall apply to operations conducted at Middlebury College.

Policy

An effective written Respiratory Protection Program shall be established, implemented, and maintained.

Responsibilities

Department Manager

Ensure there is a written Respiratory Protection Program developed, implemented, and maintained to ensure the safe use of respiratory protection equipment required on site.

Manager/Supervisor

Ensure that feasible engineering controls are implemented as the preferred method of controlling exposure to airborne contaminants in the workplace.
Ensure employees use respirators only when they are certified to do so and in a manner consistent with the requirements of this written Respiratory Protection Program and any associated training.
Assist the EHS Coordinator in identifying areas requiring the use of respiratory protection. These areas may include, but not be limited to, maintenance, construction, engineering and/or emergency response situations.
Maintain knowledge and skills in order to ensure that respirators are used properly, safely, and according to the requirements of this written program.
Identify persons working in areas where respiratory protection is or should be required.
Inform EHS of any changes in workplace conditions that may necessitate the use of respiratory protection, or the arrival of new employees who might be required to use respirators.
Maintain a list of certified respirator users, including the type of respirator to be used and date of expiration of certification.
Respirators may only be purchased if approved by EHS. (exception: Health Center may use appropriate respirator protection approved by the College physician)
Ensure that only respirators approved by EHS for the specific job are purchased and utilized by employees.
Ensure that respirators are maintained in a clean and sanitary condition.
Schedule respirator users for certification or recertification, as required.
Conduct periodic audits of respiratory protection usage to ensure that it is being properly used and maintained.
Inform potential employees that facial hair, which interferes with respirator fit, is not permitted with full face; half face or SCBA respirators.

Employees

Use respirators only when certified to do so.
Use only assigned respirators in accordance with certification, instruction, and training received.
Do not purchase respirators without EH&S approval.
Obtain medical clearance prior to initial use of respirators and as required by the Respirator Exam Policy.
Report any changes in health conditions or health problems that may be related to the use of respirators to the EHS Coordinator as soon as they occur. Inform supervisor of any health conditions that may be aggravated by the use of a respirator.
Perform tasks requiring the use of respiratory protection only when such equipment is available and in usable condition.
Only use respirators that are clean and in good condition. Report problems with a respirator to your supervisor.
Only use respirators issued by Middlebury College and approved by EHS for the specific job.
Perform pre-use inspections and self-administered fit tests on respirators prior to use.
Clean and sanitize respirators after each use and return them, properly bagged, sealed, or otherwise protected to their storage location. Change cartridges as required by usage.
Self contained breathing apparatus (SCBAs) must be returned to Its location with used cylinders replaced with fully charged cylinders. Safety shall be notified after use, if applicable. The user will make arrangements to have cylinders refilled (by Facilities or EHS).
Monthly inspections are required to insure their readiness.
When not in use, store respirators in a clean and sanitary condition.
Maintain respirators, as required.

Contract Employees

If predetermined in contract terms and conditions, contract employees may be permitted to be issued and use respiratory protective equipment supplied by us.
Shall satisfy and show proof that training and medical approval requirements, at least equal to those that are required of our employees performing the same task, have been met before donning ANY respirator.
Shall be allowed to use respiratory protection on site only after the contractor’s written Respiratory Program has been reviewed and approved by the EHS.

Environmental, Health and Safety Coordinator

Assist in assuring that feasible engineering controls are the primary method of controlling exposure to airborne contaminants in the workplace.
Assist management and consult in the development, operation, and maintenance of the site’s written Respiratory Protection Program and all associated standard operating procedures.
Maintain the written program, procedures, and records, including the list of certified respirator users.
Perform air sampling or otherwise evaluate the need for respiratory protection.
Designate operations or situations for which respirators are mandatory or authorized. Determine which type of respirator is required.
Ensure that all respirators are being properly selected, used, and are repaired and maintained according to vendor specifications.
Conduct or arrange for respiratory protection training and fit testing.
Conduct audits of the Respiratory Protection Program to ensure program effectiveness and compliance. The results of these inspections and any corrective actions taken shall be documented.
Ensure that a process exists so that respiratory equipment for emergency use, such as self-contained breathing apparatus (SCBA), is cleaned and reactivated after use, if applicable.
Ensure that breathing air is of acceptable quality, at least Grade D air as described in the Compressed Gas Association Commodity Specification G-7.1-1968 is used. Oxygen shall not be used for breathing air.
Ensure that breathing air and cylinders are tested for oxygen and carbon monoxide (CO) content, if applicable.

Definitions

Air Purifying Respirator - A respirator in which ambient air is passed through an air-purifying element that removes the contaminant(s). Air is drawn through the air-purifying element by means of the breathing action. These types of respirators are variously called disposable air purifying, particle removing, dust masks, cartridge type, negative pressure, and air purifying.

Confined Spaces - A space that, by design, has limited openings for entry and exit, could have unfavorable natural ventilation that could contain or produce dangerous air contaminant levels, and is not intended for continuous employee occupancy.

Contaminant - A harmful, irritating, or airborne nuisance material present in ambient air.

Disposable Respirator - A respirator for which maintenance is not intended and is designed to be discarded after excessive resistance to breathing develops, there is sorbent exhaustion, physical damage, it is soiled from use, or end of service life renders it unsuitable for use. At a minimum, these respirators shall be approved for toxic dusts. Nuisance dust respirators shall not be permitted.

Engineering Controls - These are the preferred methods of control of exposure to contaminants. They may include, but not be limited to any of the following or a combination of local exhaust ventilation, enclosures, isolation, and wet methods.

Exposure Limit - The maximum allowable concentration of a contaminant in the air to which an individual may be exposed. These concentrations may be time-weighted averages, short-term limits, or ceiling limits.

Immediately Dangerous to Life or Health (IDLH) - Any atmosphere that poses an immediate hazard to life or poses immediate irreversible debilitating effects to health.

Powered Air-Purifying Respirator (PAPR) - A respirator in which ambient air is drawn through an air-purifying element that removes contaminant(s). Air is drawn through the air-purifying element by means of a battery operated blower. These can be half or full face or hoods and provide air under positive pressure.

Pressure-Demand self-contained Breathing Apparatus (SCBA) - An atmosphere supplying respirator in which the breathing air is carried by the wearer in a cylinder. Such a respirator maintains a constant positive pressure within the faceplate supplying additional breathing air when the positive pressure is reduced inside the faceplate by inhalation.

Qualitative Fit Test - A pass or fail fit test that relies on the subject’s sensory response to detect the test material, such as irritating smoke or banana oil, and therefore tests the effectiveness of the respiratory protection.

Quantitative Fit Test - A fit test that uses an instrument to measure the challenge agent and, therefore, the effectiveness of the respiratory protection. A numerical protection factor is determined for each respirator user.

Program Requirements

Respirator Selection

Respirator selection shall be according to the following criteria:

Be based on hazard(s) to which employees are or may be exposed.
Be appropriate for the specific hazard and only for use in specified locations.
Selection considerations shall be defined and include, but not be limited to the following: (See Appendix A.)
Determined prior to respirator selection and periodically reviewed during respirator use
Type and concentration of air contaminant
Location, frequency, and physical aspects of the job

Available Respirator Types: The type, concentration of contaminant present, and situation will determine the type of respiratory protection required. This equipment shall be used under the conditions for which it was designed and approved.

Disposable Air Purifying Masks or Dust Masks are single-use disposable respirators. They shall, at a minimum, be approved for toxic dusts.

Air Purifying, Cartridge/Canister, and Negative Pressure Respirators consist of a full- or half-face mask and are equipped with cartridges specific to the contaminant that is present.

Notes on Air-Purifying Respirators

The proper choice of the cartridge or canister is critical. The use of the wrong cartridge or canister will cause the wearer to be unprotected. They shall not be used under IDLH conditions.

They shall not be used in atmospheres where the concentration of oxygen is less than 19.5% by volume.

They shall not be used in atmospheres where the manufacturer’s recommended maximum use concentration of the cartridge will be exceeded.

Chemical/cartridge or canister respirators shall not be used for protection against air contaminants that cannot be detected by odor or irritation at concentrations below the occupational exposure limit, or for which olfactory fatigue may occur rapidly at high exposure levels.

Chemical cartridges or canisters shall be approved for the particular contaminant of concern.

Powered Air-Purifying Respirator (PAPR) is similar, in function, to negative pressure cartridge respirators. The difference being that air is mechanically filtered rather than being drawn through the filters by breathing action. See above “Notes on Air-Purifying Respirators.”

Pressure-Demand self-contained Breathing Apparatus (SCBA) consist of a full-faceplate mask attached to a fully portable compressed breathing air tank worn by the user. SCBAs to be used in an emergency response only shall be wall mounted or otherwise easily available in pairs near where they may be needed. SCBAs may also be required for non-routine tasks, such as confined space entries. Designated SCBAs may be used for non-routine operations potentially involving oxygen deficient atmospheres and IDLH conditions.

Special Site or Process Requirements may justify the need for other types of respiratory protection. These types of respirators may include:

Supplied air pressure demand airline
Supplied air pressure demand airline with escape SCBA (Hip-pak)
Supplied air continuous flow.
EHS must approve the use of these types of equipment and will detail any special precautions.

Issuance of Respirators

The following restrictions apply to the issuance of respirators.

Respirators shall only be issued to those employees approved by EHS. Anyone issuing respirators must check the approval list first.
SCBAs shall be used for emergency response and other specifically predesignated tasks. Regardless of the application, certification is required for the use of SCBAs.
Medical staff may be cleared by the College physician for N95 masks only.

Hazard Evaluation and Respirator Selection

Respirator usage shall be based on the review of an operation or location with the potential for actual exposure to harmful levels of contaminants in the work environment.

The evaluation of a hazard shall be conducted before commencing a routine or non routine task that has the potential to require the use of respiratory protection.

Respirators shall be used only with prior (EH&S) authorization until feasible engineering controls can be instituted. Situations include, but are not limited to the following:

In response to an existing condition.
In the event of a process change that could potentially generate unknown levels of workplace environmental contaminants.
In response to complaints regarding chemical odors, irritation, or other symptomatic factors that indicate unknown and potentially excessive levels of airborne chemical vapors, mists, fumes, gases, or particulate are present in the work environment.
For a designated and required emergency response activity.

Prior to the issuance of a respirator, an evaluation of the environment in question shall be conducted by department management or supervision and EHS to determine whether respirators shall be required. The evaluation shall include, but not be limited to, a review of the following areas.

The work area including its size, equipment layout, the type of ventilation and its effectiveness, additional contaminant control measures, and the general environmental conditions
Employee activity including the number of people involved, job routines, work location, amount of time spent in the area, and work rates
Known potential inhalation hazards including chemical components, type of contamination, and toxicity and occupational health hazard data
Available industrial hygiene data including measurements of levels of contaminant performed by a competent person

Respirators shall not be used in lieu of feasible engineering controls that may include, but are not limited to local exhaust ventilation, enclosures, isolation, and wet methods.

Mandatory Use of Respiratory Protection

A list of construction (shop), maintenance, and emergency response activities that require the use of respiratory protection shall be developed and maintained by EHS.
Specialized programs for construction, maintenance, and emergency activities that require the unique use of respiratory protection shall be developed and maintained.

Authorized Use of Respirators

Employees may elect to request the use of a respirator for certain maintenance activities for which the use of a respirator is not mandatory.
Authorization shall be obtained from the EHS.
A list of construction, maintenance, and emergency response activities where respiratory protection is authorized shall be developed and maintained.
Such use of respirators shall comply with all requirements of the written Respiratory Protection Program.
Nonmandatory use of respirators is discouraged.

Other Uses for Respirators

A requirement for temporary, non routine use of respirators may arise. The requirement shall be added to the documented list of activities where temporary, non routine use is either required or authorized.

Respirator Certification Training and Fit Testing

Respirator users shall be certified as having successfully fulfilled medical evaluation, training, and fit testing requirements prior to respirator use.

Requests for Certification

Individuals requiring or requesting certification to use a respirator shall first notify their Manager/Supervisor.
A Manager/Supervisor is responsible to ensure that employees are wearing the proper respiratory protection while performing tasks that require mandatory or authorized respiratory protection.
The employee must have current respirator medical approval before attending required respirator training and fit testing.
Certification with the associated training, medical clearances, and fit testing shall be required upon initial assignment and, thereafter, at least annually or sooner should the conditions of use change, or there is a change in the physical condition of the user.

Medical Approval

Medical evaluation is required prior to employee certification and use of respiratory protection in accordance with this policy.

Certain usage of respiratory protection does not require medical evaluation. Exceptions are determined by EHS on a case by case basis, such as for the non-mandatory use of dust respirators or N95 masks for Medical personnel.

The doctor will certify the employees ability to wear a respirator. All medical information collected as part of this exam will be kept confidential.

Recommendations regarding use of respirators will be communicated to the EHS Coordinator.

Doctor’s exam required on initial application and every five years thereafter for negative pressure respirators. SCBS require an annual exam. Employee will certify medical condition annually or when there is a change in medical condition that could have an adverse effect on wearing a respirator.

Upon completion of the exam, the doctor can notify EHS of the results via the Respirator Evaluation Notification form (see appendix).

Employee health issues that may arise during the course of respirator use will be managed by EHS and recommendations will be made regarding continued ability to use respirators.

Training

Training shall be documented and presented to the appropriate groups. An individual who will be wearing a respirator must have medical approval prior to attending a training session. No one shall don a respirator without having first received medical approval.

Managers/Supervisors of employees using respiratory protection:

Review of basic respiratory protection
Discuss regulations concerning respirator use
Discuss the nature and extent of respiratory hazards to which persons under supervision may be exposed
Recognize and resolve issues pertaining to respirator use
Discuss the principles and criteria for selecting respirators used by persons under their supervision
Training of respirator users
Fitting and issuance of respirators
Inspection of respirators
Use of respirators, including monitoring of usage
Maintenance and storage of respirators

Those with the responsibility of issuing respiratory protection:

Standard operating procedures concerning respirator use
Ensure the respirator is correct for each application, and is issued only to certified users

Respirator users:

The need for respiratory protection
Regulations concerning respirator use
The nature, extent, and effects of respiratory hazards in the workplace
The need to inform supervisors of any problems experienced by respirator users or their coworkers
An explanation of why engineering controls are not being applied or are not adequate. What effort is being made to reduce or eliminate the need for respirators
An explanation of why a particular type of respirator has been selected for a specific respiratory hazard
An explanation of the operation, capabilities, and limitations of a selected respirator
Instructions for inspecting and donning the respirator. This includes a requirement that a fit check shall be done each time the respirator is donned or adjusted.
Successful completion of a fit test
An explanation of how to maintain and store a respirator
Instructions regarding emergency procedures

Respirator Fit Testing Protocol

The respirator fit testing protocol shall be designed and performed by the EHS Department or its designee.

Medical approval is a prerequisite for participating in fit testing.
Proper fit shall be determined before respiratory protection is issued and worn.
Fit tests shall be repeated whenever a new respirator is issued.
Fit tests are only valid for the particular type, brand, and model of respirator for which the testing is performed. It must be repeated should the type, brand, or model of respirator be changed.
Scheduling shall be the responsibility of the Manager/Supervisor and the user.
Employees who are not able to pass the fit test shall not be certified to wear a respirator.
Employees not certified to wear respirators shall not perform jobs that require respirators.

The following qualitative fit testing protocol, at a minimum, shall be performed to certify adequacy of respirator fit for all respirators (N95) excluding the dust mask and continuous flow type.

Irritant smoke or isoamyl acetate (banana oil), or other approved method.
Negative pressure test
Positive pressure test

Quantitative fit testing may be required for any or all of the following reasons:

To comply with specific regulatory requirements
To comply with specific policies, standards, and guidelines
If the potential exposure is sufficiently critical to require an additional level of assurance that the respirator seal is sufficient.

Facial Hair, Eye and Face Protection and Corrective Lenses

Facial hair - Respirators shall not be issued to anyone with facial hair that interferes with the respirator seal or the normal functioning of the exhalation valve.
Eye and face protection - Goggles, face shields, safety glasses, or welder’s helmet may be worn only if they do not interfere with the positioning or seal of the respiratory protection device.
Corrective lenses - Contact lenses shall not be worn while using a respirator. Where required, special prescription glasses that fit securely inside the respirator shall be worn. Special glasses shall be through the department. Use of corrective lenses with half- or quarter-mask - The lenses must not interfere with the fit or positioning of the respirator. Use of lenses with full face mask - Corrective lenses with full temple bars that interfere with proper fit are not permitted. Corrective lenses with partial temple bars or that can be secured inside the respirator and do not interfere with the positioning or seal of the respiratory protection device, shall be provided for those who are required to use such equipment as part of their job responsibilities.

Maintenance of Records of Training and Fit Testing

Records of training and fit testing shall be maintained.
Fit testing records shall include the following information.
Type of respirator fit test(s) used, including the specific fit test protocol and pass/fail criteria
Type of fit test instrumentation and equipment used and the calibration, maintenance, and repair, where applicable
Name and employee number or identification of the test operator
Name and employee number or identification of the person tested
Date of test
Results of fitting test

Fit factor based on quantitative fit test(s). To pass, requires a fit factor at least 10 times greater than the assigned protection factor for a particular respirator.

Success or failure to obtain a satisfactory fit based on qualitative fit test(s).

Any special considerations or difficulties pertinent to the wearer, such as the requirement that protective equipment or corrective lenses be worn, the need for dentures, the presence of scars, and so forth.

Respirator Inspection, Maintenance, Cleaning, and Storage

Inspection

Before donning a respirator, the wearer shall inspect it for defects according to training given.
Employees using a cartridge or canister respirator not equipped with an end-of-service-life indicator (ESLI) shall replace the cartridge within six months of use. Each cartridge should be dated at the time it is put in service.
Under no circumstances shall a respirator with a known defect be used. It shall be either repaired by a qualified person, according to the manufacturer’s instructions or replaced.
Respirators that are worn or have deteriorated shall be repaired by a qualified person or replaced prior to use.
Respirators intended for emergency use, such as self-contained Breathing Apparatus (SCBAs), shall be thoroughly inspected after each use as well as monthly, according to the manufacturer’s recommendations. These inspections shall be documented and the records retained.
Air used in SCBAs shall meet grade D breathing air specifications, or equivalent.

Oxygen and carbon monoxide (CO) testing shall be done on all sources of compressed breathing air. Acceptable levels shall be oxygen (20-22%) and CO (not to exceed 5 parts per million).

Maintenance

Maintenance shall be done only by designated persons properly trained to do so.
No repairs or modifications shall be attempted by other than a person properly trained according to the manufacturer’s specified procedures, and using only parts supplied by the manufacturer. The use of one manufacturer’s parts on another manufacturer’s respiratory protection device is not permitted.
SCBA repairs shall be performed by an approved manufacturer or qualified vendor, as necessary.
Spent SCBA air tanks shall be refilled after each use. Maintenance and refilling of cylinders and exchange of spent cylinders with full ones shall be ensured.
Regardless of the reason, breathing air is the only gas that shall be introduced into any compressed breathing air system.

Cleaning

Cleaning shall be done according to specified manufacturer protocols.
Respirators used on a routine basis shall be cleaned and sanitized daily after use. Filters and cartridges shall be replaced, as required by use. (see 2.4.1)
Respirators in use on a non-routine basis shall be cleaned and sanitized after each use and filters and cartridges replaced.

Storage

Respirators shall be stored in a clean, sanitary location close to the area requiring their use.
Negative pressure respirators shall be stored in such a manner that the cartridges are protected from air contamination which will degrade the filter media. Airtight plastic bags or similar arrangements are required to protect the cartridge media
Emergency use respirators, such as SCBAs, shall be stored where they are easily accessible in case of emergency. They shall not be stored in an area where an actual emergency would prevent access.

Audit

There shall be regular reviews to ensure the continued effectiveness of the Respiratory Protection Program.

Observed deficiencies shall be documented and corrected immediately.

The audit of the Respiratory Protection Program shall include, but not be limited to the following details.

Program administration
Training
Medical evaluations and approvals
Fit testing
Air sampling and hazard classification
Selection, issue, and use of respiratory protection
Equipment cleaning, inspection, and maintenance
Breathing air supplies
Storage
Emergency preparedness
Special issues

The following is a list of the documentation that shall be maintained as part of this program.

The Written Respiratory Protection Program Document: Contains site specific operating procedures and guidelines.
Mandatory or Authorized Uses Document: Lists activities for which respirator use is mandatory, or non mandatory but authorized, and the type of respiratory protection required for each instance.
Training and Fit-Testing Examinations: Documents training programs, written tests, and fit-testing protocols administered as part of the certification process.
Respiratory Protection Equipment Maintenance File: Contains hydrostatic testing records and other manufacturer and regulatory requirements, if applicable
SCBA Inspection Checklist: Report form that is filled out on a monthly basis as part of monthly inspection activities, if applicable.
Inspection Tags: Tags that are affixed to individual SCBAs, if applicable.

Use of Approved Respirators

Respirators must be approved by the U.S. National Institute for Occupational Safety and Health (NIOSH) and/or the U.S. Mine Safety and Health Administration (MSHA).

Self-Contained Breathing Apparatus (SCBA)

The buddy system is required for the use of SCBAs or airline respirators, regardless of whether it is a routine or non routine activity.

SCBAs designated for emergency use shall be available in pairs so they are easily accessible in an emergency. Spare cylinders, where provided, shall also be available in pairs.

SCBA Use

Employees shall be medically qualified and trained in the operation and use of the SCBA.
Training shall be consistent with the anticipated use of the equipment, whether for routine or emergency purposes.

ERT staff and trained firefighters are the only ones approved to use SCBAs.