16.5 Respiratory Protection & PPE Program Management

16.5 Respiratory Protection & PPE Program Management

The BCSP blueprint asks for knowledge of basic hazard controls to reduce exposures created by health or physical hazards, and for the skill to utilize resources to address, modify, or eliminate them. Personal protective equipment is the last of those resources, and it is the one where safety management professionals spend the most time and get the least protection per dollar — because PPE does not remove the hazard, it interposes a barrier that depends on correct selection, correct fit, correct use for the whole exposure, correct maintenance, and a worker who is medically able to tolerate it. Every one of those is a failure point.

The professional discipline is therefore to treat a PPE requirement as evidence that a higher-order control is absent or incomplete, and to document why. A hazard assessment that concludes "wear gloves" without asking whether the hazard could be enclosed, ventilated, or substituted has skipped the analysis.

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The Written Hazard Assessment

29 CFR 1910.132(d) requires the employer to assess the workplace to determine if hazards are present, or likely to be present, that necessitate PPE. If so, the employer must select and require the use of PPE that properly fits each affected employee, communicate selection decisions to each affected employee, and verify the assessment through a written certification identifying:

• the workplace evaluated,
• the person certifying that the evaluation was performed, and
• the date(s) of the hazard assessment, with the document identified as a certification of hazard assessment.

Training under 1910.132(f) must cover when PPE is necessary, what PPE is necessary, how to don, doff, adjust and wear it, its limitations, and its proper care, maintenance, useful life, and disposal. Employees must demonstrate understanding before performing work requiring PPE, and retraining is required when workplace changes, PPE changes, or inadequacies in an employee's knowledge or use render prior training obsolete.

Payment. 29 CFR 1910.132(h) requires the employer to provide PPE at no cost to the employee. The exceptions are narrow and frequently overstated by employers: non-specialty safety-toe protective footwear and non-specialty prescription safety eyewear where the employer permits them to be worn off the job site; everyday clothing and ordinary weather gear; and, where the employee has lost or intentionally damaged PPE, the replacement. Employer payment is also not required for the logging boots covered by 1910.266(d)(1)(v).

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The Respiratory Protection Program

Where respirators are required, 29 CFR 1910.134(c) requires a written program with worksite-specific procedures, administered by a suitably trained program administrator, covering: respirator selection; medical evaluation; fit testing; use in routine and reasonably foreseeable emergency situations; cleaning, disinfecting, storage, inspection, repair, discarding and maintenance; adequate air quality, quantity and flow for atmosphere-supplying respirators; training on hazards and on proper use; and procedures for regularly evaluating program effectiveness.

Selection and Assigned Protection Factors

Respirator selection is arithmetic before it is preference. The assigned protection factor (APF) is the workplace level of respiratory protection a properly functioning respirator is expected to provide to properly fitted and trained users. Selection requires an APF that reduces the expected exposure to at or below the exposure limit — expressed as the maximum use concentration (MUC) = APF × exposure limit.

Two rules constrain the arithmetic. The MUC never exceeds the IDLH concentration — for atmospheres immediately dangerous to life or health, or oxygen-deficient atmospheres, only a pressure-demand SCBA or a pressure-demand airline respirator with an auxiliary self-contained air supply is acceptable. And for a helmet or hood PAPR or continuous-flow respirator, the 1,000 figure may be used only where the manufacturer has evidence from testing the specific model demonstrating that level of performance; otherwise 25 applies.

Fit Testing and Seal Checks

• Fit testing is required for all tight-fitting facepieces, before initial use, whenever a different respirator facepiece is used, and at least annually thereafter, using an OSHA-accepted qualitative or quantitative protocol. Qualitative fit testing may be used only for respirators with an APF of 10 or less.
• Additional fit testing is required when the employee, the program administrator, a supervisor, or the health care professional reports changes affecting fit — weight change, facial scarring, dental changes.
• A user seal check is performed each time a tight-fitting respirator is donned. It confirms the seal on that occasion; it is not a substitute for fit testing.
• Facial hair that comes between the sealing surface and the face, or that interferes with valve function, disqualifies the wearer from a tight-fitting respirator. This is not negotiable and cannot be cured by a tighter strap. A loose-fitting PAPR is the usual accommodation.
• Corrective lenses or other equipment must not interfere with the seal, and spectacle kits are required for full facepiece users who need vision correction.

Cartridges and Change Schedules

For gas and vapor removal, the employer must either use a respirator with an end-of-service-life indicator (ESLI) certified for the contaminant, or implement a change schedule based on objective information or data that will ensure cartridges are changed before the end of their service life. Relying on warning properties — smell, taste, irritation — is not acceptable, because many contaminants have poor warning properties, olfactory fatigue sets in, and individual thresholds vary widely. Particulate filters are changed on increased breathing resistance, damage, or contamination, and per the manufacturer's instructions.

Voluntary Use

Where an employee voluntarily wears a respirator that is not required, the employer must determine that the use itself will not create a hazard, and must provide the information in Appendix D. For filtering facepieces only (the common disposable N95), that is the extent of the obligation. For voluntary use of any other respirator, the employer must also provide medical evaluation and ensure cleaning, storage, and maintenance — which is why an employer permitting voluntary elastomeric half-mask use has taken on most of a program without necessarily realizing it.

Senior manager pitfall. Auditing PPE compliance by counting whether people are wearing it. The questions that determine whether the program protects anyone are whether the assessment was written and current, whether the selected respirator's APF actually covers the measured exposure, whether the wearer was medically cleared and fit tested this year, whether a change schedule exists, and whether the employer paid for it.