When working with hazardous materials, elimination, substitution, engineering controls, and safe work practices are the primary means to prevent employee overexposure to hazardous airborne materials. However, when these control methods are not sufficient, feasible, available, or when potential high exposure to hazards/risks prompts additional protection/mitigation, then wearing a respirator may be necessary. Major types of respirators include:
- Air Purifying Respirators (APRs, used for protection against particulates only)
- Filtering Facepiece Respirators such as disposable N95
- Elastomeric half-face respirators with replaceable filter/cartridges
- Elastomeric full-face respirators with replaceable filters/cartridges
- Powered air purifying respirators (PAPR)
- Supplied Air Line Respirators (SALR)
- Self Contained Breathing Apparatus (SCBA)
Users who are required to wear respiratory protection must follow OSHA’s Respiratory Protection Standard (RPS) (29 CFR 1910.134). Selecting and using a respirator at JSNN will require the supervisor and Research Operations and Environmental Health and Safety (ROEHS) review and pre-approval. The following are the core elements of OSHA’s respiratory protection program:
- Written respiratory protection program (RPP) with lab-specific procedures for respirator use
- Medical evaluations
- Fit testing
- Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations
- Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators
- Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators
- Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations
- Training of employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance
- Procedures for regularly evaluating the effectiveness of the program
JSNN-ROEHS will oversee the site specific aspects of the respirator protection program.The JSNN Respiratory Protection Program can be used as the site-specific written program if the forms and documents included in the appendices I-VI are completed and maintained up to date. ROEHS will provide first testing and training and will assist PIs/labs with the development of the site specific program.
Roles and responsibilities
- Principal Investigators (PIs)
- Perform PPE assessment and identify students/employees who need respiratory protection and refer them to ROEHS
- Make sure that all individuals who are required to wear a respirator have completed and stay current with their medical, fit test, and training requirements
- Develop written SOPs/procedures for activities requiring a respirator
- Makes sure that all students/employees have access and use the respirators for the intended tasks, as identified by PI and approved by ROEHS
- Report any concerns or deficiencies to ROEHS for proper action
- Respirator users
- Follow the respirator use requirements provided by ROEHS respiratory protection training
- Wear the respirator as instructed by the PI and ROEHS
- Inspects the respirators on a monthly basis and before and after each use
- Understand the limitations and report any malfunction or concerns to the PI for proper action
- Stay updated with the annual fit testing and training requirements
- JSNN ROEHS
- Develops and implements the JSNN Respiratory Protection Program
- Provides guidelines for respiratory protection compliance
- Provides required training and fit testing for the respiratory users
- Supports PIs and users with their regulatory compliance requirements
- Maintains training and fit testing records
Respiratory Exposure Hazard Assessment and Selection
The mandatory use of respirators can be based on exposure to hazardous substances above the occupational exposure limit (PEL, TLV, etc.). The initial step in the process is to perform a respiratory exposure hazard assessment. If there is any reason to believe that respiratory protection may be necessary, a respiratory exposure hazard evaluation for each operation, process, or work area will need to be conducted. This can be done by completing the JSNN Respiratory Exposure Hazard Questionnaire (REHQ) . This form needs to be completed and forwarded to JSNN ROEHS (firstname.lastname@example.org). If it is determined that respiratory protection is warranted, ROEHS will stipulate what type of respirator is appropriate for the specific exposure hazard. The supervisor will keep a copy of the completed form.
Respirator selection requires correctly matching the respirator with the hazard, the degree of hazard/risk, and the user. The following guidance and selection factors are used in this process:
- OSHA Technical Manual Section VII, Chapter 2.V. Respirator Selection
- OSHA’s Etools Respirator Selection
- NIOSH Respirator Selection Logic
All respirators must be certified by the National Institute for Occupational Safety and Health (NIOSH) and shall be used in accordance with the terms of that certification.
Students/employees who need to use respirators must be able to tolerate the physical and psychological stress imposed by respirator use. Individuals will not be allowed to wear respirators until a physician or other licensed health care professional (PLHCP) has determined that they are medically able to do so. Individuals who forgo the medical evaluation cannot work in an area or process requiring respirator use. The only exception to this medical evaluation is voluntary or comfort-use of filtering facepiece (N-95) respirators.
The following table provides a summary on the types of respirator, application, medical evaluation, and frequency of medical evaluations for JSNN respirator users:
Infectious gents, metal/toxic particles
and when change in health status or deemed needed by healthcare provider
Half/Full-Face negative pressure air purifying or
Powered Air Purifying Respirator (PAPR)
Medical exam. Additional medical exams if deemed needed by healthcare provider
Medical exam. Additional medical exams if deemed needed by healthcare provider
Note: This medical requirement and frequency is for compliance with OSHA’s Respiratory Protection Standard only. There are different medical surveillance requirements and frequencies for employees who would come under other OSHA standards (silica, asbestos, lead, etc….).
All respirator users, including required use of a filtering facepiece (N-95) shall:
- Complete and submit the JSNN Respiratory Exposure Hazard Questionnaire (REHQ). JSNN-ROEHS needs to review and approve the form.
- Complete the medical exam at a qualified center, using the
- Medical Exam Request From . After the review of this form by the healthcare provider (HCP), the respirator users will either be cleared for respirator use, or scheduled for a follow-up medical examination
- OSHA Respirator Medical Evaluation Questionnaire (This is confidential medical information and the employee must complete this questionnaire without help from their supervisor. Their supervisor must not look at or review the answers on this form)
- Obtain and bring a signed copy of the Respirator Use Medical Approval Form to JSNN-ROEHS. The employee and supervisor will receive a copy of the written recommendations, which will indicate whether or not they have been cleared to wear a respirator, and if there are limitations on such use. Information concerning diagnosis, test results, or other confidential medical information will not be disclosed to their employer.
- Complete the JSNN respiratory protection training
- Complete the JSNN fit testing procedure (using their own respirator)
- Stay updated with the respiratory inspection, clean up, and annual training and fit testing
A powered air-purifying respirator (PAPR) must be provided to any employee if information from the HCP indicates that the employee can use a PAPR, but not a negative pressure respirator. If, subsequent to this evaluation, the HCP determines that the employee is able to wear a negative pressure respirator, the employer will no longer be required to provide a PAPR to that employee.
Additional medical evaluation or medical re-evaluation for any employee would be required when:
- The employee reports medical signs or symptoms that are related to the employee’s ability to use a respirator
- The PHCP, supervisor, or the respirator program administrator observes that the employee is having a medical problem during fit testing or workplace respirator use
- Information from the respiratory protection program, including observations made during fit testing and program evaluation, indicates a need for employee re-evaluation
- A change occurs in workplace conditions (e.g., physical work effort, type of respirator used, protective clothing, and temperature) that may result in a substantial increase in the physiological burden placed on an employee
The flowchart below illustrates steps needed for the respiratory protection compliance:
Training and Fit Testing
Each employee required to wear a respirator must be trained prior to initial use. For continued respirator use this training must be repeated at least every 12 months. The training must include at the least the following information:
- Why the use of a respirator is needed;
- What the respirator can and cannot do to protect the user;
- How to properly inspect, put on, take off, and use the respirator;
- How to check the seal of the respirator (also called a “user seal check”);
- How to use the respirator effectively in emergency situations, including situations in which the respirator doesn’t work properly;
- How to recognize medical signs and symptoms that may limit or prevent the safe use of a respirator;
- How improper fit, usage, or maintenance can reduce the respirator’s ability to protect the user;
- What the procedures are for maintenance and storage of the respirator; and
- What are the requirements for OSHA’s Respiratory Protection Standards and JSNN Respiratory Protection Program.
JSNN ROEHSwill offer either classroom or on-line general training on proper respirator use.
In addition to the general training, site-specific training will need to be conducted by a supervisor. This training focuses on the specific practices and policies of the worksite and the employees’ responsibilities.
Fit-testing and fit-checks are important to ensure that there is a good seal between the face and respirator facepiece. For respirators which require a tight seal, beard growth is not permitted. Fit testing will be required for all employees who are required to wear a tight-fitting facepiece respirator and shall be performed:
- After an employee has completed a medical evaluation and prior to being allowed to wear any respirator with a tight fitting facepiece in the work environment
- Whenever a different respirator facepiece is used
- At least annually thereafter
- When there are changes in the employee’s physical condition that could affect respiratory fit (e.g., obvious change in body weight, facial scarring, etc.)
Employees will be provided with several models and sizes of respirators so that they may find the optimal fit. JSNN ROEHS can provide fit testing as part of the hands-on training.
Chemical Cartridge and Filter Replacement Schedule
A Respirator Cartridge Change Schedule must be developed for cartridges or canisters used with air-purifying respirators that do not have an End of Service Life Indicator (ESLI). The purpose of this is to prevent contaminants from breaking through the respirator’s sorbent cartridge(s), and thereby over-exposing employees. A cartridge replacement schedule is followed based on manufacturer breakthrough test data and/or OSHA guidance. The following links provide direction on this issue:
- Department of Labor Respirator Change Schedules
- 3M Respirator Cartridge and Filter Replacement Program
Chemical cartridges should not be used for more than 6 hours in dry conditions and no more than 4 hours in humid environments. Cartridges should not be left on respirators after use. For respirators worn exclusively for protection against particles, filters will be changed according to the manufacturer’s specification and whenever the wearer detects an increase in breathing resistance. It is the responsibility of the supervisor to ensure that the change schedule is complete and updated as necessary.
Inspection, Cleaning, Storage, & Maintenance
Respirators should be inspected before and after each use, and during cleaning and sanitizing. During the inspection, the condition of the facepiece, straps, valves, filter and/or cartridge elements, air hose, and protective lens (full face or units with hoods) should be checked. If parts are worn or defective, make certain that the unit is repaired or replaced. Be alert that not all respirators have replaceable parts. Respirator parts for different brands, (i.e Scott or 3M), are not interchangeable. If in doubt, contact JSNN- ROEHS (email@example.com).
Respirators, including Self Contained Breathing Apparatus (SCBA), maintained for emergency use, must be inspected monthly and after each use. Respirators that are maintained for use in emergencies will be certified by documenting the date that the inspection was performed, the name or signature of the inspector, the findings of the inspection, any required remedial action, and a serial number or other means of identifying the inspected respirator. This inspection shall follow the manufacturers’ instructions.
Respirators will be cleaned and disinfected using the manufacturer’s recommendations for each respirator. The frequency of cleaning and disinfecting as follows:
- Respirators that are issued for the exclusive use of an employee will be cleaned and disinfected as often as necessary to be maintained in a sanitary condition. Employees will be responsible to clean and disinfect respirators issued for their exclusive use..
- Respirators maintained for emergency use will be cleaned and disinfected after each use.
Store respirator to protect against dust, sunlight, extreme temperatures, physical damage, and moisture. Use a separate bag to store filters and cartridges. All respirators are to be maintained according to the manufacturer’s recommendations.
Breathing Air Quality
The supervisor will ensure that breathing air for atmosphere-supplying respirators will be of high purity, meets quality levels for content, and does not exceed certain contaminant levels and moisture requirements.
For supplied-air respirators (SARs), only Grade D breathing air shall be used in cylinders. Supervisor shall coordinate deliveries of compressed air with the approved vendor and require certification that the air in the cylinders meets the specifications of Grade D breathing air. Moisture content in the cylinders will not exceed a dew point of –50 °F (-45.6 °C) at 1 atmosphere pressure. Note: This requirement will prevent respirator valves from freezing, which can occur when excess moisture accumulates on the valves. All breathing gas containers must be marked in accordance with the NIOSH respirator certification standard, 42 CFR part 84.
Compressors used for supplying breathing air must be constructed and situated so contaminated air cannot enter the air-supply system. The location of the air intake will be in an uncontaminated area where exhaust gases from nearby vehicles, the internal combustion engine that is powering the compressor itself (if applicable), or other exhaust contaminants being ventilated will not be picked up by the compressor air intake.
Compressors will be equipped with suitable in-line, air-purifying sorbent beds and filters to further ensure breathing air quality and to minimize moisture content so that the dew point at 1 atmosphere pressure is 10 °F (5.56 °C) below the ambient temperature. Sorbent beds and filters will be maintained and replaced or refurbished periodically according to the manufacturer’s recommendations. An inspection tag will be kept at the compressor indicating the most recent change date and the signature of the Program Administrator or designee authorized to perform the maintenance. Only non-oil-lubricated compressors will be used.
The supervisor will ensure that the compressor intake will not allow the introduction of carbon monoxide greater than 10 parts per million (ppm) into the system.
Note: This could be from sources other than the compressor such as forklifts/vehicles or other gas-powered equipment.
Breathing air couplings must be incompatible with outlets for non-respirable plant air or other gas systems to prevent accidental servicing of airline respirators with non-respirable gases or oxygen. No asphyxiating substance (e.g., nitrogen) will be allowed in the breathing airlines.
Voluntary use of N95
Voluntary or comfort users of respirators form must be submitted before voluntary use is permitted while working at JSNN.
The JSNN-ROEHS will retain a copy of the HCP’s written recommendation for each employee subject to medical evaluation. Each employee’s completed medical questionnaire, results of relevant medical tests, examinations, and diagnosis, etc., will be maintained by the HCP for a period of 30 years. Records of medical evaluations will be made available as specified in 29 CFR 1910.1020. The JSNN ROEHS will retain fit test records for respirator users until the next fit test is administered. These records consist of:
- Name or identification of the employee tested.
- Make, model, and size of the respirator fitted.
- Date of the fit test.
- Fit factor and other records of the test.
The JSNN ROEHS will retain employee training records that include the names of employees trained and the dates when training was conducted.
A current copy of the written respiratory protection program will be kept online. All written materials are required to be maintained under the recordkeeping requirements, and will be made available, upon request, to the employee who is subject to the records.
The supervisor is responsible to conduct evaluations of the workplace, as necessary and inform ROEHS of any changes. Periodic program evaluation is required to ensure that the provisions of the respiratory protection program are being implemented for all employees using respirators. In addition, evaluations will be conducted to ensure the continued effectiveness of the program. Evaluations of the workplace will determine whether the correct respirators are being used and worn properly and will also serve to determine whether the training program is effective. The supervisor is responsible to periodically monitor employee use of respirators to ensure that they are being used and worn properly.
Supervisors, in conjunction with ROEHS will also regularly consult with employees wearing respirators to ascertain the student/employees’ views on program effectiveness and to identify any problems so that corrective action can be taken.
The following factors will be evaluated to determine program effectiveness:
- Respirators are properly fitted and if employees are able to wear respirators without interfering with effective workplace performance.
- Respirators and filters/cartridges are correctly selected for the hazards encountered.
- Respirators are used properly depending on the workplace conditions encountered.
- Respirators are being maintained and stored properly.
The Program Administrator will be responsible to correct any problems associated with wearing a respirator that are identified by employees or that are revealed during any other part of this evaluation.