Respiratory Protection Program

PRINT VERSION

rev 3/2012

Purpose

• To establish guidelines for the appropriate health and safety requirements that must be followed by Hampshire College employees and outside contractors when performing work that requires the use of respirators.
• To ensure compliance with all local, state, and federal regulations, including the OSHA Respiratory Protection Standard, 29 CFR1910.134.
• To promote awareness of the potential hazards.
• To prevent injury.

This program contains operating procedures for Hampshire College employees using respiratory protection equipment. This program is given to all employees who wear respirators, as well as to their supervisors and department heads. The director of environmental health and safety administers the program and reviews the effectiveness of the program at least annually.

I. Choosing a Respirator

The facilities and grounds director or paint or carpentry department supervisors are responsible for determining when a respirator is needed to comply with OSHA Permissible Exposure Limits. Respirators may also be used under other conditions when respirator use is considered prudent by the facilities and grounds director, supervisors, or the director of environmental health and safety. Prior to making a decision that respirators are required, the feasibility of achieving compliance through engineering controls, (e.g., improved ventilation), source reduction (e.g., use of less or a different chemical), or altering work practices is evaluated. In determining the appropriate respirator, the supervisor evaluates: 

• the nature of the hazard
   physical/chemical properties (e.g., dust, vapor)
   concentration of the chemical
   permissible exposure limit
   IDLH (immediately dangerous to life and health concentration)
   warning properties of the chemical (e.g., odor)
  
  Note: Hampshire College personnel are not permitted to work in oxygen-deficient atmospheres or perform any work for which the use of a supplied-air respirator would be required.
• the nature of the operation and work area
• NIOSH-approved respirator for the contaminant 

If necessary, the supervisor seeks assistance from the facilities and grounds director or the environmental health and safety director.

A. Health Hazards and Warning Properties of the Contaminant

When choosing the type of respiratory protection required for a particular operation, the nature of the hazard must be clearly defined. Respirators are used to reduce employee exposure to a contaminant to a level below OSHA-established Permissible Exposure Limits. Information on the potential health effects of overexposure and physical properties of the chemical are available on the container label and the MSDS for the product. The MSDS for the product being used and any air monitoring data available should be reviewed before a respirator is selected. Appendix A includes definitions for chemical characteristics used to define the nature of the hazard.

It is important to recognize that respiratory protection reduces exposures from inhalation of the contaminant. For certain chemicals, skin and eye contact and/or absorption are also important routes of exposure, in which case additional personal protective equipment is required.

Air-purifying respirators can only be used for gas and vapor contaminants that have adequate warning properties that will alert the user to respirator malfunction. A chemical has adequate warning properties when the odor, taste, or irritation effects of the substance are detectable and persistent in concentrations at or below the PEL.

If the odor or irritation threshold occurs at concentrations greater than three times the PEL, the substance is considered to have poor warning properties and an air-purifying respirator cannot be used. The only exceptions to this rule are for respirators with end-of-life service indicators (e.g., carbon monoxide) or when an OSHA Standard permits such use. When the odor threshold is above the PEL, but not in excess of three times the PEL and there is no ceiling limit, potential exposures must be evaluated to determine if there could be serious of irreversible health effects. If no such effects are evident, an air-purifying respirator may be used.

B. Types of Respirators and Protection Factors

There are several basic types of respirators as listed below. The National Institute of Occupational Health and Safety (NIOSH) approves respirators.

Atmosphere-Supplying Respirators

Pressure-demand SCBA (self-contained breathing apparatus): A supply of air is continuously provided to the mask from a compressed air tank(s) carried by the individual with positive pressure maintained in the mask at all times. (Compressed air must meet grade D breathing air standards.) 

Note: Hampshire College personnel are not permitted to wear, or perform, work that requires SCBAs.

Pressure-demand Airline Respirator: A supply of air is continuously provided through a small diameter hose from a remotely located compressor or compressed-air cylinders. (Compressed air must meet grade D breathing air standards.)

Air-Purifying Respirators

Air-purifying respirator: Ambient air is passed through a filter, cartridge, or canister that removes the contaminants. The breathing action of the user draws air through the system.

Powered air-purifying respirator: Ambient air is passed through a filter, cartridge, or canister that removes contaminants. A blower worn by the user forces air through the system.

Air-purifying respirators do not protect against oxygen-deficient atmospheres and cannot be used under IDLH conditions. The maximum contaminant concentration in which an air-purifying respirator can be used is dependent on the design efficiency and capacity of the filter or cartridge and the face-piece to face seal on the user.

Air-purifying respirators can only be used for certain ranges of air contaminant concentrations. A respirator protection factor (RPF) has been established for each type of respirator based on the overall effectiveness of the respirator. The RPF is a ratio of the air contaminant concentration outside the respirator to the air contaminant concentration inside the respirator face piece (breathing air). RPFs are used in conjunction with PELs to determine the upper concentration limit [maximum use concentration (MUC)] for which the respirator is acceptable.

For example, a half-face cartridge respirator with organic vapor cartridges has an RPF of 10. It can be used when air contaminant levels are less than 10 times the PEL, the MUC. In some cases, the MUC based on 10 times the PEL is too high, and a lower MUC has been established. A full-face air-purifying respirator has an RPF of 50. Some examples of MUCs for half-face cartridge respirators are provided in Table 1. NIOSH-approved MUCs can be found in the NIOSH Pocket Guide to Chemical Hazards.

The proper type of filter or cartridge must be chosen for the contaminant of concern. Filters and cartridges are classified into two major types: particulate-removing and vapor/gas-removing. Particulate-removing filters and cartridges provide no protection against vapors and gases. Only cartridges for a particular manufacturer and model respirator may be used.

Multiple cartridges may be used if approved by the manufacturer. Cartridges available include:

• acid gas
• organic vapor
• organic vapor/acid gas
• ammonia/methylamine
• chlorine
• carbon monoxide gas
• acid gas/organic vapor/carbon monoxide
• dust/fumes/mists

Air-Filtering Disposable Masks (N95)

On occasion, employees may elect to wear a disposable mask when a respirator is not required by OSHA standards. These employees are directed to OSHA's Information for Employees Using Respirators When Not Required Under the Standard (see Appendix D).

Appendix E shows respirator program requirements for required and voluntary use of respirators.

C. NIOSH-Approved Respirators

Specific contaminant(s) and concentration(s) must be evaluated to identify those respirators with NIOSH/MSHA or OSHA approval for the conditions of use. The NIOSH Pocket Guide to Chemical Hazards identifies for each contaminant the MUC for each type of approved respirator. For example, for acetone, a half-face chemical cartridge respirator with organic vapor cartridges can be used for concentrations at or below 2500 ppm.

Respirators are approved as a whole unit with specific components. Only components (e.g., cartridges, filters, gaskets, straps) approved for the respirator may be used. Components from different brands of respirators cannot be interchanged.

D. Respirator Use on Campus

The following operations may require respirator use. Supervisors determine if respirators are needed for a specific job.

All respirators are issued by the employee's supervisor or the director of environmental health and safety. Respirators are only issued to employees after successful completion of the medical evaluation (see section II) and instruction (see Section VII).

Outside contractors are required to have and follow their own written respiratory protection program as well as all applicable regulations. Contractors that may be in this category are pesticide applicators, pool maintenance companies, etc.

II. Medical Requirements of the Program

The Respirator User Medical Questionnaire, included in Appendix B, is required by OSHA. This questionnaire is confidential and administered annually to all employees in the Program. Responses are evaluated by the AEIOU occupational health clinic to determine if a medical examination is needed and the extent of that examination. Examinations are provided by AEIOU. Employees may discuss the results of the questionnaire or examination by contacting AEIOU.

AEIOU provides a written recommendation before an employee begins participation in the Respiratory Protection Program and annually thereafter. The recommendation includes any limitations on respirator use related to the medical condition of the employee, the need, if any, for follow-up medical evaluation, and a statement that a copy of the recommendation has been sent to the employee. Additional medical evaluation will be provided if an employee reports medical signs or symptoms that are related to ability to use a respirator.

Any medical records generated by this program that are in the possession of the College are retained for a period of thirty years and are accessible to employees, (or their designated representative), as required by the OSHA Access to Medical Standard. Employee medical records are retained at Hampshire College human resources.

III. Respirator Use

A. Workplace Surveillance

Before commencing work that requires a respirator, employees should familiarize themselves with:

• the warning properties of the chemicals involved, such as
   odor
   appearance and color
   irritant effects 
   symptoms of overexposure
• engineering and administrative controls, such as
   ventilation
   recommended work practices
• other personal protective equipment such as
   gloves, aprons, etc. to prevent skin contact           
   goggles or face shield to prevent eye contact

Questions regarding any of these factors are addressed by the supervisor.

B. Approved Respirators

Only respirators purchased by the College are used. All respirators are NIOSH-approved for the hazard encountered. An employee can only use a respirator the same make, style, and size for which he or she has been fit-tested.

C. Prohibiting Conditions

Respirators cannot be worn by people with beards. Other conditions may also prevent adequate face-piece to face seal such as sideburns, absence of one or both dentures, or temple bars on glasses (when wearing full-face respirators).

D. Donning the Respirator

A user seal check is performed every time a respirator is put on. Seal check methods are described in Section V and practiced during training.

E. Evaluation of Respirator Effectiveness

The supervisor will determine the requirements for surveillance of the work area to identify any changes in area conditions or employee exposure to stress that could affect respirator effectiveness. Employees must leave the work area:

• to wash face and respirator as necessary to prevent eye or skin irritation associated with respirator use,
• if they detect vapor or gas breakthrough, changes in breathing resistance, or leakage of the face piece,
• to remove the respirator for any reason.

IV. Respirator Care and Maintenance

A. Cleaning

All respirators are issued to individual users and are not shared. Respirators are regularly cleaned with soap and water by the user. Respirators routinely used throughout the day are cleaned after each day's use or more often as necessary. Respirators used for short intermittent periods of time may be cleaned with less frequency with, at a minimum, cleaning after 8 hours of use. When used in particulate-contaminated areas, respirators, even when used for short periods, are cleaned after each use. The following general cleaning procedure is used: 

1. Remove cartridges, filters, valves, and straps.
2. Wash face-piece and accessories (not cartridges) in warm soapy water. Gently scrub with a brush.
3. Rinse parts thoroughly with clean water.
4. Air-dry in a clean place or wipe dry with a clean, lintless cloth.
5. Inspect for wear or defects and reassemble.

B. Inspection

Respirators should be inspected each time they are used:

1. Check face-piece for pliability, deterioration, and cracks, tears, or holes.
2. Check straps for breaks, tears, loss of elasticity, or broken attachments.
3. Check filters or canisters for dents, corrosion, or expiration dates.
4. Check valves for pliability, deterioration, or tears.
5. Confirm that the filter or canister is acceptable for the hazard that is present.
6. For cartridges with "end-of-service life" indicators, confirm that it is still in the usable range.

If any part of the respirator is unacceptable, replace that part or the entire respirator before use.

C. Cartridge Service Life

Cartridges must be replaced when there is "breakthrough" of the contaminant. This is evident by recognition of the taste, odor, or irritant effects of the contaminant. They must also be replaced when breathing becomes difficult or any deterioration or visible dirt is noticed. At a minimum, cartridges should be changed after 8 hours of use or, if used for less than 8 hours per month, at least monthly. The date a cartridge is removed from the package must be written on the cartridge before installation. A limited number of cartridges (e.g., carbon monoxide) have visible "end of service life" indicators that must be checked each time the respirator is used.

D. Storage

Respirators are stored in a convenient, clean, and sanitary location and protected from dust, chemicals, sunlight, excessive heat or cold, and moisture. Respirators must be closed in sealed plastic bags or containers. Storage location should be determined by the employee with approval of his/her supervisor.

V. Donning a Respirator

A. Restrictions on Use

Respirators cannot be worn under conditions that may interfere with the facial seal. Such conditions include:

1. a beard, sideburns, or other facial hair at the face-piece to face seal under the face piece,
2. temple bars on glasses (full face respirators), and
3. the absence of one or both dentures.

Respirator use may also be restricted based on the results of the physical examination described in Section II.

B. Fitting Instructions and Pressure Testing

After inspection of the respirator, the user should don the respirator in a clean environment. Make sure the respirator is assembled correctly.

Manufacturer's recommendations regarding donning procedure should be followed. In general, the donning sequence for a half-face respirator should be:

1. place face-piece over face
2. pull crown strap over head
3. hook lower headband strap behind neck
4. adjust lower headband
5. adjust crown strap.

The respirator should not be over-tightened so as to be uncomfortable on the face. After donning a cartridge respirator, the user should peform a negative and positive pressure test to verify that the respirator is sealed properly.

To perform the negative pressure test, cover the cartridges with the palm of your hand, inhale, and hold your breath for at least ten seconds. The face-piece should collapse slightly and no inward leakage of air should be detected. 

To perform the positive pressure test, cover the exhalation valve with the heel of your hand, and exhale gently. A slight positive pressure should build up within the mask and no outward leakage of air should be detected.

The respirator should not be adjusted after entering the hazardous environment. If adjustment is necessary, the employee should first go to a clean environment.

VI. Respirator Fit-Testing

Respirator fit-testing is used to determine if a particular respirator is sized properly for the user. Fit-testing is only applicable to cartridge and negative pressure respirators. Only respirators, (identified by manufacturer, model, and size), for which an acceptable fit has been demonstrated may be used.

Employee fit-testing is conducted prior to initial use of a different respirator face-piece, (size, style, model, or make), and at least annually thereafter. Additional fit-testing is done if an employee reports, or the supervisor observes, a change in physical condition that could change the fit of the respirator. Fit-testing is done using the Portacount quantitative fit-testing protocol or the procedure defined in Appendix A, B.5. of the OSHA Standard, Irritant Smoke Protocol, as summarized in Appendix C.

VII. Employee Training and Records

Instruction on the proper use and limitations of respiratory protection equipment is given prior to respirator use and at least annually thereafter. Training is provided by the director of environmental health and safety. Original training records are kept by the director of environmental health and safety, with copies kept by each department. The training includes the following topics:

• respirator selection
• medical evaluation
• fit-testing
• respirator use
• respirator care and maintenance

Appendices

A. Chemical Hazard Definitions
B. Medical Questionnaire
C. Respirator Fit-Testing
D. Dust Mask Respirators 
E. Respirator: Use Requirements