IUPUI Environmental Health & Safety

Industrial Hygiene > RESPIRATORY PROTECTION PROGRAM

INDIANA UNIVERSITY-PURDUE UNIVERSITY at INDIANAPOLIS
IUPUI
• Office of Environmental Health and Safety •
620 Union Drive, Room 043, Indianapolis, Indiana 46202

Purpose and Background
The IUPUI Department of Environmental Health and Safety (EHS) has developed this policy to ensure a safe work environment and to protect the health and safety of IUPUI faculty, staff, and researchers who are potentially exposed to airborne contaminants or may occupy an oxygen deficient atmosphere. The Occupational Safety and Health Administration (OSHA) promulgated a final rule 29 CFR 1910.134. This standard applies to all employees who are required to wear a respirator for any of their job tasks.

Scope
This policy applies to all IUPUI faculty and staff who are exposed to airborne contaminants that cannot be controlled through engineering or administrative controls. Employees who anticipate wearing respiratory equipment during an emergency incident are also covered.

Policy
This policy has the following objectives:

Identify employees that are exposed to hazardous levels of airborne contaminants or become involved in tasks that take place in oxygen deficient atmospheres;

Choose a respirator and filter or cartridge that will offer adequate protection. If a filter or cartridge doesn’t offer adequate protection a supplied air respirator may need to be used;

Fit test all employees who are required to wear a respirator during their work tasks; and

Train employees required to wear a respirator on the proper use, maintenance and storage of the respirator.

No employee of IUPUI shall be issued or required to wear a respirator until the need for such protection is validated by EHS and the affected employee has met the criteria set forth by OSHA.

Authority and Responsibility
EHS shall be responsible for:

Developing, implementing, and administering IUPUI’s Respiratory Protection Program;

Identifying work areas within IUPUI facilities that have a need for employees to use a respirator and perform evaluations;

Performing all necessary personal air monitoring to determine exposure to potentially hazardous airborne contaminants;

Determining if engineering and administrative controls can be put in place to eliminate exposure to airborne hazards;

Providing training and fit testing to employees who are required to use a respirator;

Ensuring that the employees are medically fit to wear a respirator;

Maintaining fit test and training records;

Reviewing and updating the program whenever new information is available; and

Ensuring compliance with all federal, state, and local regulations.

The Departments shall be responsible for:

Identifying employees that are working with or have the potential to be exposed to hazardous airborne contaminants;

Providing the appropriate work practices and engineering controls to control hazardous airborne contaminants;

Providing necessary respiratory protection for all faculty and staff;

Providing necessary equipment so that the user is able to clean and disinfect their personal respirator after each use;

Ensuring that all faculty and staff who are assigned to workplaces where there is exposure to hazardous airborne contaminants have received the proper training, fit testing, medical evaluation and proper equipment;

Enforcing the proper use and maintenance of respiratory equipment as necessary; and

Coordination and consulting with EHS to determine who has the potential for exposure to hazardous airborne contaminants.

The Employees shall be responsible for:

Completing the mandatory medical questionnaire and any medical evaluation requirements deemed necessary by the evaluating physician;

Attending annual respiratory training and fit testing;

Performing care and maintenance of the respirator;

Using the respirator correctly and conducting the proper pressure checks each time the respirator is donned;

Notifying his/her supervisor of any problems with the respirator or concerns about exposure to hazardous airborne contaminants.

Notifying his/her supervisor of any other respiratory hazards that has not been adequately addressed; and

Maintaining facial surface consistent with a proper fit of the respirator (i.e., no facial hair that comes between the sealing surface of the face piece and the face or that interferes with valve function).

Contractors or other non-university employees shall be responsible for:

Developing and implementing a respiratory protection program for their employees who work on IUPUI property and could be exposed to hazardous airborne contaminants above Occupational Safety and Health Administration (OSHA) established permissible exposure limits (PEL’s). This program must meet OSHA regulations and include issuance of respirators, medical evaluations, fit testing and training.

IUPUI Health Services shall be responsible for:

Reviewing medical evaluation forms to determine if an employee is medically fit to wear respiratory protection equipment;

Determining what tests, evaluations or medical checks are necessary to make the determination if an employee is medically fit to wear respiratory protection equipment;

Providing a follow-up medical evaluation for any employee who demonstrates the need for a follow-up medical examination based on responses from the questionnaire;

Conducting routine medical examinations to determine if respirator wearers have been exposed to harmful levels of respiratory hazards; and

Maintaining records as prescribed in the Recordkeeping section.

Permissible Practice
In the control of those occupational diseases caused by breathing air contaminated with harmful dusts, fog, fumes, mists, gases, smokes, sprays, or vapors, the primary objective shall be to prevent atmospheric contamination. This shall be accomplished as far as feasible by accepted engineering control measures (for example, enclosure or confinement of the operation, general and local ventilation, and substitution of less toxic materials). When effective engineering controls are not feasible or while they are being instituted, appropriate respirators shall be provided and used pursuant with this policy when such equipment is necessary to protect the health of the employee.

Voluntary Use of a Respirator
Where respirator use is not required, respirators may be provided at the request of the employees or employees shall be permitted to wear their own respirator, if EHS determines that the respirator use will not in itself create a hazard.
If EHS determines that a voluntary respirator is permissible, Appendix D of this document, “Information for Employees Using Respirators When Not Required under the Standard – Appendix D of 29 CFR 1910.134” shall be provided.
Each employee using a respirator voluntarily shall meet the medical criteria of this program to ensure he/she is medically able to use the respirator. The employee shall follow all cleaning, storage, and maintenance requirements in this program to ensure that the respirator does not present a health hazard to the user.

Exception: This does not apply to the voluntary use of filtering facepieces (dust masks).

Selection and Types of Respirators
EHS shall identify and evaluate respiratory hazard(s) in the workplace for each operation, process, or work area where airborne contaminants may be present in routine operations or in emergencies. This evaluation shall include a reasonable estimate of employee exposures to respiratory hazard(s) and identification of the contaminant’s chemical and physical form. Where employee exposure cannot be identified or reasonably estimated, the atmosphere shall be considered to be immediately dangerous to life and health (IDLH).

There are two basic classes of respirators: air purifying and atmosphere supplying.

Air-purifying respirators use filters or sorbents to remove harmful substances from the air. They range from simple disposable masks to powered air-purifying respirators (PAPR’s). Air-purifying respirators do not supply oxygen and may not be used in oxygen-deficient atmospheres or in areas that are immediately dangerous to life or health (IDLH).

Atmosphere-supplying respirators are designed to provide breathable air from a clean air source other than the surrounding contaminated work atmosphere. They range from supplied-air respirators and self-contained breathing apparatus (SCBA's) to complete air-supplied suits.

Selection of the type of respirator to be used will be based on the potential hazard involved. Essential information which will be obtained and evaluated in selecting the type of respirator includes:

The potential of working in an oxygen deficient atmosphere;

The hazardous airborne contaminants to which employees may be exposed;

The form of the contaminants gas, vapor, dust, mist, fume, or combination;

The concentration of expected hazardous airborne contaminants;

IDLH levels and permissible exposure limits (PEL’s) for the contaminants;

Flammable limits, odor thresholds, and other properties of the contaminants;

Recommended protection factors for specific types of respirators;

The likelihood of obtaining a proper fit;

Comfort of the user relative to heat, humidity, and other conditions;

Compatibility with heavy equipment and chemical protective clothing; and

Availability of essential supplies, such as cartridges, and repair parts.

Once the general type of respirator has been selected for the job, the make, model and size will be chosen from those approved by the National Institute for Occupational Safety and Health (NIOSH) for the contaminant involved.

Respirators for IDLH Atmospheres
For protection from IDLH atmospheres, one of the following shall be provided:

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 (SAR) with auxiliary self contained air supply.

Respirators provided only for the escape from IDLH atmospheres shall be NIOSH-Certified for escape from the atmosphere which they will be used.All oxygen-deficient atmospheres shall be considered IDLH.

Gas and Vapor Protection

For protection against gases and vapors, one of the following respirators shall be provided;

An atmosphere-supplying respirator; or
An air-purifying respirator, provided that the respirator is equipped with an end-of-service-life-indicator (ESLI) certified by NIOSH for the contaminant or when there is no ESLI appropriate for conditions in the work place, EHS shall implement a change schedule for canisters and cartridges that is based on objective information or data from the respirator manufacturer that will ensure that canisters and cartridges are changed before the end of their service life.

Particulate Protection

For protection against particulates, one of the following respirators shall be provided:

An atmosphere-supplying respirator; or

An air-purifying respirator equipped with a filter certified by NIOSH under 30 CFR part II as a high efficiency particulate air (HEPA) filter, an air purifying respirator equipped with a filter certified for particulates by NIOSH under 42CFR part 84; or

For contaminants consisting primarily of particles with mass median aerodynamics diameters (MMAD) if at least 2 micrometers, an air-purifying respirator equipped with any filter certified for particulates by NIOSH.

Tuberculosis Exposure (TB) and other Infectious Disease Control

For protection against Tuberculosis or other infectious diseases, one of the following respirators shall be provided:

A NIOSH approved N-95 particulate respirator which meets CDC guidelines for TB exposure control; or
A powered air purifying respirator (PAPR) in combination with a high efficiency particulate air (HEPA) filter, and head cover or hood.

Medical Evaluation
Using a respirator may place a physiological burden on employees which vary with the type of respirator work, the job and workplace conditions in which the respirator is being worn and the medical status of the employee.

General Requirements
A medical evaluation is required by OSHA's Respiratory Protection Standard (29 CFR 1910.134) for employees who wear respirators. OSHA requires that the medical evaluation consist of, at minimum, completion of the Respiratory Medical Evaluation Questionnaire by the employee and review of the questionnaire by a licensed health care professional or competent person. This requirement is intended to ensure that employees are physically able to wear a respirator.

Medical Evaluation Procedures
Employees shall obtain and complete a medical questionnaire by contacting Environmental Health and Safety or by visiting the website at www.ehs.iupui.edu. All completed questionnaires shall be returned to EHS in a sealed enveloped marked “confidential” for review by IUPUI Health Services.
The Respiratory Medical Evaluation Questionnaire (Appendix A) shall be administered confidentially during the employee's normal working hours or at a time and place convenient to the employee. If the employee needs assistance in filling out or understanding the questionnaire, IUPUI Health Services will provide assistance, so as to maintain confidentiality.

Environmental Health and Safety shall provide the following information to IUPUI Health Services prior to the clinic making a recommendation concerning an employee's ability to use a respirator:

The type and weight of the respirator to be used by the employee;

The duration and frequency of respirator use (including use for rescue and escape);

The expected physical work effort;

Additional protective clothing and equipment to be worn;

Temperature and humidity extremes that may be encountered;

A copy of IUPUI’s Respiratory Protection Program; and

A copy of 29 CFR 1910.134.

IUPUI Health Services shall provide a written recommendation regarding the employee's ability to use the respirator including any 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. IUPUI Health Services shall also identify the need, if any, for follow-up medical evaluations.

Follow-up Medical Examination
A follow-up medical evaluation shall be required for employees giving a positive response to any question among questions 1 through 8 in Section 2, Part A of the questionnaire.
The follow-up medical examination shall include any medical tests, consultations or diagnostic procedures that the physician deems necessary to make a final determination for clearance of respirator usage.

Additional Medical Evaluations
Additional medical evaluations shall be provided if:

An employee reports medical signs or symptoms that are related to the ability to use a respirator;
IUPUI Health Services, the supervisor or representative from EHS recommends a re-evaluation;
Information from the respiratory protection program, including observations made during fit testing and program evaluation, indicates a need for employee re-evaluation; or
A change occurs in workplace conditions (e.g., physical work effort, protective clothing, temperature) that may result in substantial increase in the physiological burden placed on an employee.

Fit Testing Procedures
Although respirators are designed for maximum efficiency, they cannot provide protection without a tight seal between the facepiece and wearer. Due to differences in facial structure and size, no one respirator will fit everyone. Selection of the appropriate size and shape of respirator and demonstration of a tight facepiece-to-face seal are the main components of fit testing.
Before an employee may be required to wear a negative or positive pressure tight fitting facepiece, the employee must be fit tested with the same make, model, style and size of the respirator to be used.
EHS shall conduct and ensure employees pass an appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT). An OSHA-accepted protocol as described in 29CFR 1910.134(f) shall be followed when conducting QLFT or QNFT.
Fit testing shall be conducted:

Prior to the initial use of any respirator with a tight-fitting facepiece;

Whenever a different respirator facepiece is used;

At least annually; or

When there are changes in the employee’s physical condition that could affect respiratory fit. Such conditions include, but are not limited to, facial scarring, dental changes, cosmetic surgery, or an obvious change in body weight.

Use of Respirators
Facepiece Seal Protection
Respirators with tight fitting facepieces shall not 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 (PPE), the employer shall 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, the employer shall ensure that employees perform a user seal check each time they put on the respirator in accordance with Appendix B – ”User Seal Check Procedures” of this document.

Continuing Respirator Effectiveness
Appropriate surveillance shall be maintained of work area conditions and the degree of employee exposure or stress. The effectiveness of the respirator shall be re-evaluated when there is a change in work area conditions or the degree of the employee exposure or stress changes.

Employees shall leave the respirator use area for the following reasons;

To wash their faces and respirator facepieces 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 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, the respirator shall be replaced or repaired prior to returning to the work area.

IDLH Atmospheres
For all IDLH atmospheres:

One employee, or when needed, more than one employee shall be located outside the IDLH atmosphere;
Visual, voice or signal line communication shall be maintained between the employee(s) inside and outside of the IDLH atmosphere; and
The Indianapolis Fire Department shall be contacted prior to entry into IDLH atmospheres to provide entry assistance, back-up assistance, and/or emergency rescue.

Maintenance & Care of Respirators

Cleaning and Disinfecting

All respirators provided to employees shall be clean, sanitary, and in good working order. Respirators shall be cleaned and disinfected using the procedures in Appendix C – “Respirator Cleaning Procedures” of this document at the following intervals:

When used exclusively by one employee, as often as necessary to be maintained in a sanitary condition;
After each use when the respirator is used by more than one employee;
When used for emergency purposes, after each use; and
After each use when used for fit testing and training purposes.

Storage

Respirators must be stored to protect against damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals. Respirators shall be packed or stored so that facepieces and exhalation valves will rest in a normal position to prevent the rubber or plastic from reforming into an abnormal shape. Respirators should be stored in the plastic bags they were delivered in for a clean and safe way of accomplishing this.

Inspection

Respirators used on a routine basis shall be inspected before each use and during cleaning. The inspection shall consist of the following;

A check of 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; and
Special attention shall be given to rubber or plastic parts for pliability and signs of deterioration.

Emergency use respirators shall be inspected before and after each use and at least monthly otherwise. SCBA's shall be inspected at least monthly by Fire Protection Services (FPS). Air and oxygen cylinders must be fully charged according to the manufacturer's instructions. Regulator and warning devices must be checked to assure their proper function.
Emergency escape-only respirators shall be inspected before being carried into the workplace for use.
Inspections of respirators maintained for emergency use shall be certified by documenting the date the inspection was performed, the name of the person who made the inspection, the findings, required remedial action and a serial number or other means of identifying the inspected respirator. This information shall be kept with the respirator and maintained until replaced with a subsequent certification.

Repairs

Respirators failing inspections or otherwise found to be defective shall be removed from service and discarded or repaired or adjusted only by experienced persons trained to perform such operations using only the respirator manufacturer’s NIOSH-approved parts specifically designed for the respirator. Repairs shall be made according to the manufacturer’s recommendations, and no attempt should be made to repair or replace components or make adjustments or repairs beyond the manufacturer's recommendations.

All compressed breathing air shall meet the requirements for Grade D breathing air described in American National Standards Institute (ANSI)/Compressed Gas Association Commodity Specification for Air, G-7.1-1989.

Identification of Filters, Cartridges, and Canisters
All filters, cartridges, and canisters used at IUPUI shall be labeled and color coded with the NIOSH approval label. The label shall not be removed and shall be legible.

Chemical cartridges shall be replaced according to manufacturer's recommendations. Mechanical filters must be replaced as necessary to avoid high resistance to breathing.

Respirator Training
Employees shall be trained prior to being required to use a respirator in the workplace. The following items should be identified during the respirator training:

Why a respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator;
Limitations and capabilities of the respirator;
Components of the respirator: head straps, facepiece seal, valves, filters/cartridges;
Pre-use inspection and evaluation;
How to properly don and doff a respirator;
Positive and negative pressure fit check procedures;
When and how to change out the filters/cartridges;
Factors that could affect the fit of the mask;
Post-use inspection;
Proper maintenance and storage of the respirator;
Cleaning and disinfecting the respirator;
How to recognize medical signs and symptoms that may limit or prevent effective use of respirators; and
The general requirements of the Respiratory Protection Standard.

Retraining
Retraining shall be conducted annually and when the following situation occurs:

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; or

Any other situation arises in which retraining appears necessary to ensure safe respirator use.

Program Evaluation
Evaluations of the workplace are necessary to ensure that the written respiratory protection program is being properly implemented. This includes consulting with employees to ensure that they are using the respirators properly. Evaluations shall be conducted as necessary to ensure that the provisions of the current written program are being effectively implemented and that it continues to be effective.
Program evaluation will include discussions with employees required to use respirators to assess the employees' views on program effectiveness and to identify any problems. Any problems that are identified during this assessment shall be corrected. Factors to be assessed 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; and

Proper respirator maintenance.

Recordkeeping

Fit Test Records

Environmental Health and Safety (EHS) shall maintain all copies of respirator training and fit-testing records for all IUPUI employees fit tested by EHS. Fit test records shall be retained until the next fit test is administered.

Fit test records for School of Medicine staff that were fit tested through IUPUI Health Services shall be maintained at IUPUI Health Services. Fit test records shall be retained until the next fit test is administered.

Medical Evaluations

Record of medical evaluations shall be retained by IUPUI Health Services for the duration of employment and 30 years thereafter.