OSHA Respiratory Protection Requirements

This article briefly explains OSHA’s respiratory-protection standard and includes information on inhalation-hazard identification and evaluation, written-plans, medical surveillance, fit tests and training.

In occupational settings, employee exposure to a wide variety of contaminants is common.  The contaminants range from naturally occurring bio-aerosols such as pollen and fungal spores to nuisance dust, toxic dusts, vapors and gasses.  OSHA’s respiratory-protection regulations, found at 29 CFR 1910.134 for general industry and 29 CFR 1926.103 for construction, provide employers with a way to protect their employees from these exposures when engineering and other controls aren’t enough.

The regulations require employer’s to develop respiratory protection programs when respirators are required to protect the health of the employee from these hazards.  In addition, many of OSHA’s substance-specific regulations require the use of respiratory protection and they reference the respiratory regulation; these include asbestos, lead, crystalline silica and many others.  Within the OSHA respiratory protection regulation, there are several mandatory requirements – We have outlined these requirements here to help you get compliant but feel free to reach out to us if you have questions.  Answers@Anfeald.com or 970-372-1131.

Step 1: Identify, Evaluate and Quantify Inhalation Hazards

The first step in managing occupational respiratory hazards is the identification and evaluation of any suspected inhalation hazards.  A knowledgeable person must complete and document a reasonable and appropriate qualitative exposure assessment to identify processes, jobs, tasks and workplace locations that expose employees to inhalation hazards.

The safety professional initially assesses and categorizes possible exposures into one of three buckets:

  1. No employee exposure
  2. Nuisance-level only exposure
  3. Periodic or continuous employee exposure

This assessment always includes visual observations but may include the use of pull-tubes, direct-read instruments, grab samples, area samples and wipe samples to confirm the presence or absence of hazardous mists, vapors or gasses and dusts.

Once the contaminants are identified, personal air sampling is performed for each exposed job title to fully characterize and quantify the exposure.  One can then compare the actual measured exposures to applicable occupational exposure limits and determine whether or not hazard controls are required.

Step 2: Identify Appropriate Hazard Controls

A careful evaluation of all control measures is required, starting first with elimination or substitution of the hazardous substance, followed by engineering controls such as ventilation and finally administrative controls such as job rotation or the scheduling of maintenance when fewer employees are present.  Ideally, respirators are the last line of defense, not the first. However, in all too many situations, respirators are required.

Step 3: Select Appropriate Respirators

Respirator selection is the next step when the controls-selection process includes the use of respiratory protection.  The selection of a respirator includes a comprehensive review of the contaminant, job tasks and other factors.  Areas of investigation and discussion include but are not limited to all of the following:

  • Evaluation of actual exposure data including the manner of exposure (misting, splashing, dust, etc.), typical and worst-case airborne concentrations
  • Comparisons of actual and anticipated concentrations against relevant exposure limits
  • The physical and chemical properties of the contaminant such as warning properties, odor threshold, vapor pressure, vapor density and other factors
  • The physical hazards of the contaminant
  • The health affects of the contaminant
  • The types of respiratory protection suitable for the application based on maximum-use and IDLH values
  • The length of respiratory protection use and conditions of use
  • The cost of the respirators and the program

Respirators come in two basic varieties:

  1. Tight-fitting, negative-pressure, air-purifying
  2. Supplied air

 

Step 4: Develop a Written Respiratory Protection Plan

The OSHA respiratory standard requires development of a written respiratory protection plan that addresses a variety of important topics from respirator selection, use, respirator maintenance, cartridge change-out schedules and other topics.

Step 5: Employees Complete Questionaires and Medical Surveilance

Before respirators are used in the workplace, each employee must complete an OSHA respirator questionnaire.  The employer must confidentially submit completed questionnaires to a medical provider, who will review them and determine whether or not the employee can safely use a respirator.  The medical provider will deliver a form to the employer with one of four outcomes:

  1. The employee may use a respirator as indicated on the form with no restrictions
  2. The employee may not use a respirator at all due to one or more health conditions
  3. The employee may use a respirator as indicated on the form subject to the restrictions described by the medical provider on the form
  4. The employee must submit to a respirator physical that typically includes spirometry (a form of pulmonary function testing)

If the medical provider requires a respirator physical, the employee must make an appointment and visit the medical provider, who will evaluate the employee and render a medical opinion on whether or not the employee can use a respirator.

It is also important to note that the employer must pay the employee for the time it takes to complete the questionnaire and complete any medical surveillance.  Anfeald provides OSHA-compliant medical-questionnaire reviews online or on paper an din Engish or Spanish.  Find out more information and how to sign up here.

Step 6: Complete Respirator Fit Tests

After the medical clearance, an initial fit test is required to ensure that the respirator fits the user since respirators are not all the same.  Each respirator brand contains unique materials, features and number of sealing surfaces. They are not one-size or one-brand fits all. The same respirator make and model is unlikely to work on an entire employee population.  The employer should select two different respirator makes and/or models with appropriate sizes to ensure proper fit. These respirators should be available during all fit testing.

Fit tests come in two varieties – qualitative and quantitative.  Qualitative fit tests involve the use of challenge agents that are either irritants or that exhibit unique properties of smell and taste. This method relies on the subjective senses of the user and is subject to error. Anfeald does not recommended qualitative fit tests if quantitative fit tests are available.

Quantitative fit tests involve the measurement of the ratio of particles inside and outside the respirator (aerosol based) or the pressure differential between the inside and outside of the respirator (controlled negative pressure based). Aerosol-based systems indirectly measure leak rate while controlled negative pressure systems directly measure leak rate.  Anfeald provides quantitative respirator fit tests using controlled negative pressure technology.

Important reminders:

  • OSHA requires both initial and annual fit tests
  • Always make sure you have respirators from two manufacturers available in different sizes during fit tests
  • Facial hair between the sealing surface and the face is contraindicated. No beards, no chops, no goatees!
Step 7: Train Employees

Respiratory protection training is required when employees wear respirators.  Initial training and periodic training on an as-needed basis are both required.  Anfeald provides training on all types of respirators.  Training course length varies.  Visit our course catalog page to search for and learn more about respiratory protection training.

Step 8: Maintain Your Program

Written program reviews, updates, period workplace exposure assessments and reassessments are all required to ensure the respiratory protection program is current and exposures assessments remain valid.  Update your program whenever workplace conditions change and at least annually.

We have compiled an FAQ on commonly asked questions about respiratory protection.  Let us know if you have additional questions or need help with your program.

Frequently Asked Questions

Respiratory Protection

When should employees complete OSHA respirator questionnaires?

OSHA requires medical clearance before fit tests.  We recommend that your employees ideally complete questionnaires two weeks in advance, whenever possible, since some employees will require a respirator physical.

Where can I get a copy of the OSHA respirator questionnaire?

If you want a paper copy, no problem.  Call or email us and we can send you a copy of the questionnaire.  Please use Anfeald’s form rather than your own as it has extra information on the form that is required by our medical staff.  Using OSHA’s standard form or your own will slow down the process.

Please also consider using the online form.  This allows processing in real-time or near real-time and completely eliminates paper.

Learn More about online questionnaires.

How long does it take to review questionnaires?

Online questionnaire reviews are fast.  Most reviews occur in real time or near real-time with results available in just a few minutes. Occasionally, the healthcare provider needs additional information – The results form will contain a request to call a phone number to discuss things with the healthcare provider.  In most cases, this will clear things up.  The faster the call is made, the faster the process goes.

When completing paper questionnaires, the turnaround time varies based on headcount.  In general, the larger the group, the more time we need.  Contact Anfeald with your needs and we will provide a turnaround estimate.  If you require same-day service, let us know – This is often possible though it may incur an additional charge.

Do all employees need a respirator physical?

In a word, no. In our experience, most employees don’t need a physical.  However, some employees surely do as a result of medical conditions and overall health issues.  You will find out for sure once the medical provider reviews the questionnaires – You will receive a form for each employee with their status.  Its always best to plan ahead and have employees complete respirator questionnaires a week or two early in case a medical exam is needed since scheduling exams sometimes takes a few days.

How many quantitative fit tests can Anfeald complete in an hour?

Test times vary – In general, if you are prepared employees are ready to go when the time comes, and respirators fit everyone, we can complete eight or ten fit tests in an hour.  However, respirators don’t always fit so we recommend planning for five fit tests an hour on average.

What is spirometry (pulmonary function testing)?

Spirometry is a common type of pulmonary function test (PFT) that measures how well a person can move air in and out of their lungs.  In occupational settings, spirometry is used to establish a baseline before assigning a worker to job tasks that are physically demanding, that require use of a respirator, or that may expose the worker to respiratory hazards.  It is also used to track lung-function over time and to evaluate workers who experience signs or symptoms of respiratory disease.  Certain OSHA standards mandate spirometry for employees.  When a medical provider requires a respirator-physical after an OSHA respirator-questionnaire review, spirometry is almost always completed as part of the physical.

It is a best practice, and an Anfeald recommendation, to complete spirometry annually with your fit tests.  OSHA and NIOSH also recommend spirometry.  It can spot lung function problems early on and it can provide valuable information on the efficacy of hazard controls.

Does OSHA require a written respiratory protection program?

Yes.  If you require respirator use, OSHA requires a written respiratory protection program for general industry and construction work in full conformance with 29 CFR 1910.134.  Anfeald can provide you with a written program.

My employees use respirators – Do I need to train them?

Yes.  OSHA requires an appropriate level of training based on the kinds of respirators used, the situations used and other factors.  Anfeald provides respiratory protection training based on your needs.  Check out our course catalog page and locate the respiratory protection class that meets your needs.

Can a respirator user have facial hair?

For proper respirator fit, nothing must interfere with the sealing surface of the respirator and the user’s face.  This includes facial hair.  We care about the safety and health of client’s employees.  Therefore, Anfeald technicians will not fit test any individual with facial hair between the face and the sealing surface; all employees must be clean-shaven though small mustaches and soul patches are OK.  There are no exceptions.

Can Anfeald supply respirators during fit tests?

Anfeald does not supply respirators unless you make special arrangements in advance.  If you would like us to supply respirators, you must notify us at least a week in advance.

We may have surrogate facepeices that can be used for fit tests from common manufacturers though you should contact us in advance to find out more as we can’t always guarantee we will have a surrogate facepiece for your brand and size.

Keep in mind that sometimes respirators just don’t fit a person, even when they previously fit.  We recommend selecting two brands and having both brands in all sizes available for fit tests.

Any other info I should know about when I schedule fit tests for my employees?

Anfeald will conduct up to three fit-test attempts for each individual presented to us.  If the individual does not successfully pass the fit test after three attempts, the respirator does not fit and Anfeald will stop fit-testing the individual on that make, model and size of respirator.

Anfeald charges fit-test fees even when the individual fails.  Anfeald considers three negative fit-test attempts as one fit-test, and charges accordingly.  If additional fit-tests are required on different makes and models of respirator, Anfeald will charge for additional fit-tests.

In order to ensure a productive and efficient fit-test session, and to comply with OSHA regulations, please have a sufficient number of respirators from at least two manufacturers on-hand the day of the fit-test; please include different sizes even though most participants fit medium.  If you would like us to bring additional respirators, please let us know in advance – Anfeald charges additional fees when we provide respirators to your employees.

Always tell us the respirators you use so we can verify that we have the correct respirator fit-test adapters.

I am an employer. How do I get access to the results portal?

In most cases, we will email login credentials to the contact person that set up the program at the time we first perform fit tests or questionnaire reviews for your company.  If you are an existing client and need access, no problem.  Let us know and we will set up access.

I lost my email and/or user name to the online data entry or results portal (or both).

No problem.  Send an email to us or call and we will get you the information.  Please keep in mind, we must establish your identify first and, you must have a current service agreement on file or we must have a credit card number on file in our system before we can reset the account.

How do I set up an account to do online OSHA respirator questionnaires?

You can set up an account by providing us information about your company and signing a service agreement with a billing program so we can invoice you each month or by providing a credit card that we keep on file that we charge after each day’s questionnaire reviews.

Respiratory Protection Services by Anfeald

Anfeald helps clients with all of the following services:

Check out our respiratory protection FAQ for more information.  Reach out to us when you are ready to talk.  We can help!

Reach Out To Us Today!

Call 970.372.1131 or send us a note

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