Establishing a compliant program can save lives.
professionals often struggle when developing a written worksite-specific
respiratory protection program. OSHA-prepared guidance materials include the
“Small Entity Compliance Guide,” which provides answers to frequently asked
questions, general information and a sample program. It can be found on theOHSA websiteunder the publications tab.
The first step in the process of developing a RPP is to conduct an industrial
hygiene audit of the workplace to assess the presence of any atmospheric contaminants.
Respiratory hazards can take the form of harmful dust, fogs, fumes, mists,
gases, smoke, sprays or vapors. The IHA will identify and categorize
contaminants that are present and will help the employer determine the steps
necessary to protect employees from those hazards.
The preferred practice to protect employees from hazards is the use of
engineering controls. However, if
engineering controls are not feasible or already are being implemented, or in
case of an emergency, §1910.134 mandates that the employer establish, implement
and maintain a written worksite-specific RPP. The program must include a
suitably trained program administrator and the provisions outlined in
If the employer’s program does not include particular elements listed in
§1910.134(c)(1), they need not be included in the program. For example, if an
employer does not use atmosphere-supplying respirators, it would not have to
include the element-concerning procedures to ensure adequate air quality.
When developing a respiratory program, employers must identify and evaluate
respiratory hazards in the workplace, identify relevant workplace and user
factors and make a reasonable estimate of employee exposure to the identified
contaminants. Based on these factors, National Institute for Occupational
Safety and health-certified respirators are selected and provided for employee
use. Respirators must be selected from a sufficient number of models, styles
and sizes to correctly fit and be acceptable to the user.
Voluntary use of respirators is only permitted when the employer determines that
the respirator itself will not create a hazard for the employee through misuse,
medical conditions, or other hazards or conditions. The voluntary respirator
use section of the program must only contain the parts pertaining to voluntary
respirator use: medical evaluations, inspection, cleaning, storage and
maintenance. A best practice would be to include a listing of employees
included in the voluntary use of respirators in an appendix of the program.
Because using a respirator may place a physiological burden on an employee, the
employer is required to provide medical evaluations administered by a
professional licensed health-care provider to those employees who wear
respirators. Medical evaluations must be performed prior to fit testing, respirator
use, when an employee reports medical symptoms related to respirator use, when
changes occur in workplace conditions, or when other circumstances indicate a
re-evaluation is needed. Medical evaluations are confidential with a pass/fail
from a PLHCP. A best practice would be to include a listing of employees
included in medical evaluations in an appendix of the program.
Employers must provide procedures for the maintenance, cleaning and
disinfection, storage and inspection of respirators used by employees. All
respirators are to be stored in such a manner that protects them from damage,
contamination, dust, sunlight, extreme temperatures, excessive moisture,
harmful chemicals and face-piece distortion and exhalation valve damage.
Respirators must be inspected before each use, with the exception of emergency
respirators and self-contained breathing apparatuses, which are inspected
monthly. Emergency respirators require certification documents to prove proper
Respiratory protection programs are complex to develop and maintain, but if
executed properly, their benefits are immeasurable.