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Confused about OSHA’s respirator standard? Don’t be. Here are answers to 12 commonly asked customer questions about respirators.

by Craig E. Colton

OSHA’s revised respiratory protection standard (29 CFR 1910.134) contains important changes that affect how companies implement and administer a respiratory protection program. As of October, companies were required to be in compliance with the standard, which applies to general industry, construction, shipyard, longshoring and marine terminal workplaces.

Overwhelmed by customer questions about the new standard? Don’t be. Here are answers to 12 commonly asked questions from end-users.

Establishing a respiratory protection program
When does a respiratory protection program have to be established?

A respiratory protection program is required whenever respirators are necessary to protect the health of an employee or are required by the employer. Respirators are necessary when the contaminant concentration to which employees are exposed exceeds the OSHA permissible exposure limit (PEL). A respirator may be required by an employer even though an OSHA standard may not require its use. An example may be when an employer chooses to control exposures to the Threshold Limit Values (TLVs‚) when TLVs are lower than the OSHA PELs.

What elements must be included in the written respiratory protection program?

According to OSHA, the following worksite-specific procedures must be included:

1) procedures for selecting respirators for use in the workplace;

2) medical evaluations of employees required to use respirators;

3) fit testing procedures for tight-fitting respirators;

4) procedures for proper use of respirators in routine and reasonably foreseeable emergency situations;

5) procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding and otherwise maintaining respirators;

6) procedures to ensure adequate air quality, quantity and flow of breathing air for atmosphere- supplying respirators;

7) training employees in the respiratory hazards they are potentially exposed to during routine and emergency situations;

8) training employees in the proper use of respirators, including placement and removal, limitations on use, and maintenance; and

9) procedures for regularly evaluating the effectiveness of the program.

If respirators are not necessary or required and I allow respirators to be used, is a respiratory protection program required?

If your exposure assessment indicates there is no exposure and using the respirator will not, in itself, pose a hazard, employers may allow employees to use their own respirators or may provide them.

In these circumstances, employers must provide respirator users with the information included in Appendix D of the standard. An employer must also set up a “limited” respiratory protection program that ensures employees are medically able to use respirators and that respirators are properly cleaned, stored and maintained so the respirator does not present a health hazard to the user. The other elements of the respiratory protection program are not required. The standard lists an exception for filtering facepiece respirators.

What if employees voluntarily choose to use filtering facepieces?

In these voluntary-use circumstances, employers need not establish a written respiratory protection program. They must, however, still provide the information contained in Appendix D of the new standard.

Can tight-fitting respirators, when used voluntarily, be worn over a beard?
Yes, provided it is used voluntarily and there is no hazard. However, in circumstances where respirators are necessary or required, the standard still prohibits the use of tight-fitting respirators by employees with beards.

Medical evaluation of respirator users
Is a medical exam required to comply with the new OSHA standard?

No, but a medical evaluation to determine the employee’s ability to use the respirator is required, and must be conducted by a physician or other licensed health care professional (PLHCP) before fit testing or using the respirator. This evaluation can be done in two ways, either by using the medical questionnaire that appears in Appendix C of the standard or by performing an initial medical exam that obtains the same information. Depending on the results of the medical evaluation or the initial medical exam, a follow-up medical exam may be required.

Does the medical evaluation have to be repeated annually?

No. According to the standard, it must be repeated only in the following situations:

• when an employee reports signs or symptoms related to the ability to use a respirator;

• if a PLHCP, supervisor, respirator program administrator or person conducting a fit test indicates an employee needs to be re-evaluated;

• or, when a change in workplace conditions (such as temperature, physical work effort or the use of protective clothing) may result in a substantial increase in the physiological burden placed on an employee.

A medical evaluation would only need to be performed annually if the PLHCP indicated employees needed to be re-evaluated annually or the respiratory protection program was written to require it.

Respirator selection
Under the new standard, how many different respirators must an employer stock?

The standard requires that employers “select respirators from a sufficient number of models and sizes so that the respirator is acceptable to, and correctly fits, the user.” It replaces requirements in the OSHA substance-specific standards that specify a particular number of respirators, such as “at least three sizes of elastomeric half facepieces and units of at least two manufacturers.”

Fit testing
What are the new requirements for fit testing?

Employees who use negative pressure or positive pressure tight-fitting respirators must pass an appropriate qualitative or quantitative fit test. Specific fit testing procedures are described in Appendix A of the standard. Employees must be fit tested with the same make, model, style and size of respirator he or she will use. Fit testing must be conducted “prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) is used, and at least annually thereafter.”

What are the requirements for fit testing of positive pressure respirators?

Fit-testing of atmosphere- supplying respirators and tight-fitting powered air-purifying respirators must be accomplished by performing qualitative or quantitative fit testing in the negative pressure mode, regardless of the mode of operation (negative or positive pressure) that is used for respiratory protection.

Respirator change schedules
Is it true I can no longer rely on warning properties to indicate when cartridges and canisters for gas and vapor respirators need changing?

Yes. When using these respirators, warning properties can no longer be used as primary indicators for change. Instead, when an air-purifying respirator is used for protection against gases and vapors, the respirator must be equipped with an ESLI (end-of-service-life indicator) that has been certified by the National Institute for Occupational Safety and Health (NIOSH) for the contaminant.

Currently, there are only a few NIOSH-approved respirators meeting this requirement. If there is no ESLI appropriate for the workplace conditions, the employer must use a change schedule for canisters and cartridges that ensures they are changed before the end of their service life. This time frame is determined by obtaining service life information, applying it to your workplace, and then establishing a change schedule.

Substance-specific standards
How does the new standard affect the substance-specific standards, such as those for asbestos, benzene, formaldehyde and lead?

The new 29 CFR 1910.134 is referred to in the substance-specific standards. The fit-testing procedures for these substances have been withdrawn. Fit-testing frequency and procedures must comply with the new 1910.134. Change schedules needn’t be established for the substance-specific standards that allow chemical cartridges or canisters. The specific standard must be followed. However, respirator selection tables, assigned protection factors (APFs) and medical surveillance requirements for the substance specific standards have not changed.

For further information

Obtain further information by consulting the standard (Federal Register 63:1152, 8 January 1998) or by checking the OSHA website: http://www.osha-slc.gov. Your respirator manufacturer also can assist you as you take steps to help your customers comply with the provisions of the respirator standard.

Craig E. Colton is a certified industrial hygienist in 3M’s Occupational Health and Environmental Safety Division. Previously an OSHA instructor, he is past chair of the AIHA Respiratory Protection Committee and is a member of the ANSI Z88.12 Committee on Respiratory Protection for Infectious Aerosols.