Respiratory Protection Program

RESPONSIBILITIES

The MSU Respiratory Protection Program requirements have been established to ensure the protection of all employees from respiratory/inhalation hazards through proper selection and use of respirators. Respirators are to be used only where engineering control of respiratory/inhalation hazards are not feasible, while engineering controls are being installed, or in emergencies. This program is in accordance with the requirements of OSHA 29 CFR 1910.134. MSU employees must comply with processes and procedures related to occupational exposure control measures such as: engineering, administrative, personal protective equipment, and participation in an occupational health surveillance program.

The program administrator is MSU Safety & Risk Management (SRM). This department manages the facets of the program and has full authority to make necessary decisions to ensure success of this program. SRM is also qualified, by appropriate training and experience that is commensurate with the complexity of the program, to administer or oversee the program and conduct the required evaluations. Department supervisors and managers are responsible for informing SRM of new hires.

RESPIRATOR SELECTION

Respirators are selected on the basis of respiratory hazards to which the employee may be exposed and workplace user factors that affect respirator performance and reliability. All selections are made via consult with SRM. Outside expertise, manufacturer's assistance, and other recognized authorities will be consulted if there is any doubt regarding proper selection. Selection procedures include coverage of the following OSHA requirements:

When selecting any respirator in general:

• Select and provide respirators based on respiratory hazard(s) to which an employee may be exposed, and corresponds to workplace and user factors that affect respirator performance and reliability.
• Select a NIOSH-certified respirator. (NIOSH = National Institute for Occupational Safety and Health)
• Identify and evaluate the respiratory hazard(s) in the workplace, including a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant's chemical state and physical form. Consider the atmosphere to be immediately dangerous to life or health (IDLH) if you cannot identify or reasonably estimate employee exposure.
• Select respirators from a sufficient number of respirator models and sizes so that the respirator is acceptable to, and correctly fits, the user

When selecting respirators for Immediately Dangerous to Life or Health (IDLH) atmospheres:

• A full facepiece pressure demand self-contained breathing apparatus (SCBA) certified by NIOSH for a minimum service life of thirty minutes, or a combination full facepiece pressure demand supplied-air respirator Self-contained breathing apparatus (SAR) with auxiliary self-contained air supply.
• Provide respirators NIOSH-certified for escape from the atmosphere in which they will be used when they are used only for escape from IDLH atmospheres.
• Consider all oxygen-deficient atmospheres to be IDLH. Exception: If MSU can demonstrate that, under all foreseeable conditions, the oxygen concentration can be maintained within the ranges specified in Table II of 29 CFR 1910.134 (i.e., for the altitudes set out in the table), then any atmosphere-supplying respirator may be used.

When selecting respirators for atmospheres that are not IDLH:

• Provide a respirator that is adequate to protect the health of the employee and ensure compliance with all other OSHA statutory and regulatory requirements, under routine and reasonably foreseeable emergency situations.
• Select a respirator that meets or exceeds the required level of employee protection by using the assigned protection factors (APFs) listed in §1910.134 Table 1. [Effective Nov. 22, 2006]
• For combination respirators (e.g., airline respirators with an air-purifying filter, ensure that the APF is appropriate to the mode of operation in which the respirator is being used. [Effective Nov. 22, 2006]
• Select a respirator for employee use that maintains the employee's exposure to the hazardous substance at or below the maximum use concentration (MUC), when measured outside the respirator. [Effective Nov. 22, 2006]
• Do not apply MUCs to conditions that are immediately dangerous to life or health (IDLH); instead use respirators listed for IDLH conditions in §1910.134(d)(2). [Effective Nov. 22, 2006]
• Set the MUC at the lower limit when the calculated MUC exceeds the IDLH level for a hazardous substance or the performance limits of the cartridge or canister. [Effective Nov. 22, 2006]
• Select respirators appropriate for the chemical state and physical form of the contaminant.
• For protection against gases and vapors, provide:
• An atmosphere-supplying respirator, or
• An air-purifying respirator, provided that: (1) The respirator is equipped with an end-of-service-life indicator (ESLI) certified by NIOSH for the contaminant; or (2) If there is no ESLI appropriate for conditions in our workplace, implement a change schedule for canisters and cartridges that is based on objective information or data that will ensure that canisters and cartridges are changed before the end of their service life.
• For protection against particulates, provide:
• An atmosphere-supplying respirator; or
• An air-purifying respirator equipped with a filter certified by NIOSH under 30 CFR part 11 as a high efficiency particulate air (HEPA/P-100) filter, or an air-purifying respirator equipped with a filter certified for particulates by NIOSH under 42 CFR 84; or
• For contaminants consisting primarily of particles with mass median aerodynamic diameters (MMAD) of at least 2 micrometers, an air-purifying respirator equipped with any filter certified for particulates by NIOSH.

MEDICAL EVALUATIONS

A medical evaluation to determine whether an employee is able to use a respirator is necessary to prevent injuries, illnesses, and even, in rare cases, death from the physiological burden imposed by respirator use. At MSU, persons will not be assigned to tasks requiring use of respirators nor fit tested unless it has been determined that they are physically able to perform the work and use the respirator.

MSU's contracted occupational medicine provider will perform medical evaluations using a medical questionnaire found in Sections 1 and 2, Part A of Appendix C of 29 CFR 1910.134. All medical questionnaires and examinations are confidential and handled during the employee's normal working hours or at a time and place convenient to the employee. The medical questionnaire is administered so that the employee understands its content. All employees are provided an opportunity to discuss the questionnaire and examination results with the medical provider. (Also see MSU's Occupational Health Surveillance Program.)

Once the medical provider determines whether the employee has the ability to use or not use a respirator, he/she sends MSU a written recommendation containing only the following information:

• Limitations on respirator use related to the medical condition of the employee, or relating to the workplace conditions in which the respirator will be used, including whether or not the employee is medically able to use the respirator;
• The need, if any, for follow-up medical evaluations

RESPIRATOR FIT TESTING PROCEDURES

It is imperative that respirators must fit properly to provide adequate protection. If a tight seal is not maintained between the facepiece and the employee's face, contaminated air will be drawn into the facepiece and be breathed by the employee. Fit testing seeks to protect the employee against breathing contaminated ambient air and is one of the core provisions of MSU's respirator program.

In general, fit testing may be either qualitative or quantitative. Qualitative fit testing (QLFT) involves the introduction of a gas, vapor, or aerosol test agent into an area around the head of the respirator user. If that user can detect the presence of the test agent through subjective means, such as odor, taste, or irritation, the respirator fit is inadequate.

In a quantitative respirator fit test (QNFT), the adequacy of respirator fit is assessed by measuring the amount of leakage into the respirator, either by generating a test aerosol as a test atmosphere, using ambient aerosol as a test agent, or using controlled negative pressure to measure the volumetric leak rate. Appropriate instrumentation is required to quantify respirator fit in QNFT.

MSU fit tests employees at the following times with the same make, model, style, and size of respirator that will be used:

• Before any of our employees are required to use any respirator with a negative or positive pressure tight-fitting facepiece;
• Whenever a different respirator facepiece (size, style, model, or make) is used;
• At least annually;
• Whenever the employee, medical provider, supervisor, or SRM makes visual observations of changes in the employee's physical condition that could affect respirator fit. Such conditions include, but are not limited to, facial scarring, dental changes, cosmetic surgery, or an obvious change in body weight; and
• When the employee, subsequently after passing a QLFT or QNFT, notifies MSU, SRM, supervisor, or medical provider that the fit of the respirator is unacceptable. That employee will be retested with a different respirator facepiece.

Employees must pass one of the following fit test types that follow the protocols and procedures contained in 29 CFR 1910.134 Appendix A:

• QLFT (Only used to fit test negative pressure air-purifying respirators that must achieve a fit factor of 100 or less. May be used to test tight-fitting atmosphere-supplying respirators and tight-fitting powered air-purifying respirators if tested in the negative pressure mode); or
• QNFT (May be used to fit test a tight-fitting half facepiece respirator that must achieve a fit factor of 100 or greater OR a tight-fitting full facepiece respirator that must achieve a fit factor of 500 or greater OR tight-fitting atmosphere-supplying respirators and tight-fitting powered air-purifying respirators if tested in the negative pressure mode).

PROPER RESPIRATOR USE PROCEDURES

Once the respirator has been properly selected and fitted, its protection efficiency must be maintained by proper use in accordance with 29 CFR 1910.134(g). The following items are to be observed to ensure that proper use procedures include coverage of OSHA requirements:

Facepiece Seal Protection

• Do not permit respirators with tight-fitting facepieces to be worn by employees who have:
  
  • Facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function; or
  • Any condition that interferes with the face-to-facepiece seal or valve function.
• If an employee wears corrective glasses or goggles or other personal protective equipment, ensure that such equipment is worn in a manner that does not interfere with the seal of the facepiece to the face of the user.
• For all tight-fitting respirators, ensure that employees perform a user seal check each time they put on the respirator using the procedures in 29 CFR 1910.134 Appendix B-1 (User Seal Check Procedures) or procedures recommended by the respirator manufacturer that you can demonstrate are as effective as those in Appendix B-1.

Continuing Respirator Effectiveness

• Appropriate surveillance must be maintained of work area conditions and degree of employee exposure or stress. When there is a change in work area conditions or degree of employee exposure or stress that may affect respirator effectiveness, reevaluate the continued effectiveness of the respirator.
• Ensure that employees leave the respirator use area:
  
  • To wash their faces and respirator facepieces as necessary to prevent eye or skin irritation associated with respirator use; or
  • If they detect vapor or gas breakthrough, changes in breathing resistance, or leakage of the facepiece; or
  • To replace the respirator or the filter, cartridge, or canister elements.
• If the employee detects vapor or gas breakthrough, changes in breathing resistance, or leakage of the facepiece, replace or repair the respirator before allowing the employee to return to the work area.

IDLH Atmospheres

• One employee or, when needed, more than one employee is to be located outside the IDLH atmosphere;
• Visual, voice, or signal line communication is maintained between the employee(s) in the IDLH atmosphere and the employee(s) located outside the IDLH atmosphere;
• The employee(s) located outside the IDLH atmosphere are trained and equipped to provide effective emergency rescue;
• The employer or designee is notified before the employee(s) located outside the IDLH atmosphere enter the IDLH atmosphere to provide emergency rescue;
• The employer or designee authorized to do so by the company, once notified, provides necessary assistance appropriate to the situation;
• Employee(s) located outside the IDLH atmospheres are equipped with:
  
  • Pressure demand or other positive pressure self-contained breathing apparatuses (SCBAs), or a pressure demand or other positive pressure supplied-air respirator with auxiliary SCBA; and either:
  • Appropriate retrieval equipment for removing the employee(s) who enter(s) these hazardous atmospheres where retrieval equipment would contribute to the rescue of the employee(s) and would not increase the overall risk resulting from entry; or
  • Equivalent means for rescue where retrieval equipment is not required under the bullet item above this one.

Maintenance and Care Procedures

In order to ensure continuing protection from respiratory protective devices, it is necessary to establish and implement proper maintenance and care procedures and schedules. A lax attitude toward maintenance and care will negate successful selection and fit because the devices will not deliver the assumed protection unless they are kept in good working order.

MSU provides each respirator user with a respirator that is clean, sanitary, and in good working order. Respirators are to be cleaned and disinfected in accordance with these procedures:

• In Appendix B-2 of 29 CFR 1910.134.
• Recommended by the respirator manufacturer.

Respirators are to be cleaned and disinfected at the following intervals:

Storage of respirators must be done properly to ensure that the equipment is protected and not subject to environmental conditions that may cause deterioration. Employees shall ensure that respirators are stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals, and they are packed or stored to prevent deformation of the facepiece and exhalation valve.

In order to assure the continued reliability of respirator equipment, it must be inspected on a regular basis. The frequency of inspection is related to the frequency of use. Here are the frequencies for inspection:

Respirator inspections shall include the following checks:

• For respirator function, tightness of connections, and the condition of the various parts including, but not limited to, the facepiece, head straps, valves, connecting tube, and cartridges, canisters or filters.
• Elastomeric parts for pliability and signs of deterioration.
• For self-contained breathing apparatus, in addition to the above, monthly, we maintain air and oxygen cylinders in a fully charged state and recharge when the pressure falls to 90% of the manufacturer's recommended pressure level and determine that the regulator and warning devices function properly.

Respirators that fail an inspection or are otherwise found to be defective are removed from service, and are discarded or repaired or adjusted in accordance with the following procedures:

• Repairs or adjustments to respirators are to be made only by persons appropriately trained to perform such operations and only with the respirator manufacturer's NIOSH-approved parts designed for the respirator.
• Repairs must be made according to the manufacturer's recommendations and specifications for the type and extent of repairs to be performed.
• Reducing and admission valves, regulators, and alarms must be adjusted or repaired only by the manufacturer or a technician trained by the manufacturer.

Training

The most thorough respiratory protection program will not be effective if employees do not wear respirators, or if wearing them, do not do so properly. The only way to ensure that MSU employees are aware of the purpose of wearing respirators, and how they are to be worn is to train them. Simply put, employee training is an important part of the respiratory protection program and is essential for correct respirator use.

Our training program provided by SRM is two-fold; it covers both the:

1. Respiratory hazards to which our employees are potentially exposed during routine and emergency situations.
2. Proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance.

The aforementioned training items are provided prior to requiring or providing an employee with a respirator. However, if an employee has received training within 12 months addressing the seven basic elements of respiratory protection (see "seven basic elements" below) and MSU and the employee can demonstrate that he/she has knowledge of those elements, then that employee is not required to repeat such training initially. Yet, MSU does require all employees to be retrained annually and when the following situations occur:

• Changes in the workplace or the type of respirator render previous training obsolete.
• Inadequacies in the employee's knowledge or use of the respirator indicate that the employee has not retained the requisite understanding or skill.
• Any other situation arises in which retraining appears necessary to ensure safe respirator use.

Seven Basic Elements

MSU employees are trained sufficiently to be able to demonstrate knowledge of at least these seven elements:

1. Why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator.
2. What the limitations and capabilities of the respirator are.
3. How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions.
4. How to inspect, put on, remove, use, and check the seals of the respirator.
5. What the procedures are for maintenance and storage of the respirator.
6. How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators.
7. The general requirements of 29 CFR 1910.134.

Information for employees using respirators when not required under OSHA

The basic advisory information on respirators, as presented below is provided by SRM in any written or oral format, to employees who wear respirators when such use is not required by the regulations or by MSU.

Respirators are an effective method of protection against designated hazards when properly selected and worn. Respirator use is encouraged, even when exposures are below the exposure limit, to provide an additional level of comfort and protection for workers. However, if a respirator is used improperly or not kept clean, the respirator itself can become a hazard to the worker. Sometimes, workers may wear respirators to avoid exposures to hazards, even if the amount of hazardous substance does not exceed the limits set by OSHA standards. If MSU provides respirators for voluntary use, certain precautions need to taken to ensure that the respirator itself does not present a hazard.

1. Read and heed all instructions provided by the manufacturer on use, maintenance, cleaning and care, and warnings regarding the respirators limitations.
2. Choose respirators certified for use to protect against the contaminant of concern. NIOSH, the National Institute for Occupational Safety and Health of the U.S. Department of Health and Human Services, certifies respirators. A label or statement of certification should appear on the respirator or respirator packaging. It will state what the respirator is designed for and how much it will protect.
3. Do not wear a respirator in atmospheres containing contaminants for which the respirator is not designed to protect against. For example, a respirator designed to filter dust particles will not protect against gases, vapors, or very small solid particles of fumes or smoke.
4. Individuals must keep track of their respirators so that someone does not mistakenly use someone else's respirator.

Program Evaluation

It is inherent in respirator use that problems with protection, irritation, breathing resistance, comfort, and other respirator-related factors occasionally arise. Although it is not possible to eliminate all problems associated with respirator use, MSU tries to eliminate as many problems as possible to improve respiratory protection and encourage employee acceptance and safe use of respirators. By having SRM thoroughly evaluate and, as necessary, revise MSU's Respiratory Protection Program, problems can be effectively addressed. At MSU, program evaluation, performed by SRM, involves the following:

• Conducting evaluations of the workplace as necessary to ensure that the provisions of the current written program are being effectively implemented and that it continues to be effective.
• Regularly consulting employees required to use respirators to assess their views on program effectiveness and to identify any problems. Any problems that are identified during this assessment must be corrected. Factors to assess include, but are not limited to:
  
  • Respirator fit (including the ability to use the respirator without interfering with effective workplace performance)
  • Appropriate respirator selection for the hazards to which the employee is exposed
  • Proper respirator use under the workplace conditions the employee encounters
  • Proper respirator maintenance

EXPOSURE INCIDENTS & INJURY REPORTING

Employees should immediately seek medical attention at Bridger Occupational Health (BOH). If treatment through BOH is unattainable for any reason, the chosen medical provider should be advised that they may contact BOH for additional consultation. BOH can be reached at (406) 586-5694 from 7:30am to 6pm Monday through Friday. After regular business hours, the Bozeman Deaconess Hospital Emergency Room can be utilized and reached at (406) 585-1000 24 hours a day.

As soon as possible following an incident, the employee and/or supervisor must notify SRM at (406) 994-6888. The employee and their supervisor must complete a First Report of Injury or Occupational Disease form, to begin the workers' compensation process. A follow-up investigation may be initiated by Safety & Risk Management as to determine the circumstances of the event, and examine potential options to prevent future occurrences.

SAFETY & RISK MANAGEMENT – CONTACT INFORMATION

Should employees have questions or require assistance with MSU's Respiratory Protection Program, the following personnel are available to assist:

Tammy Lynn
Health & Safety Specialist
406-994-7384
tammy.lynn@montana.edu