Millions of employees wear respirators on a daily basis, but many of their employers are not in compliance with the applicable OSHA requirements for Respiratory Protection 1910.134 which applies to construction as well as general industry. The most common mistake construction employers make associated with respirator use is handing out filtering face pieces (dust masks) without any consideration for the OSHA requirements, which in many situations requires the employer to develop and implement a written respiratory protection program. This would include job-specific procedures for required and voluntary respirator use.
What Is a Respirator?
A respirator is a device that is worn over the mouth and nose, sometimes full-face, that protects the worker from inhaling dangerous particles or chemicals, such as asbestos fibers, silica dust or chlorine gas above safe levels known as the permissible exposure level (PEL) or threshold limit value (TLV). These levels are established based on a worker exposure averaged over an 8-hour workday.
Selecting the right respirator requires a workplace assessment of operations that may create a respiratory hazard. The identity of the hazard and its airborne concentrations need to be determined before choosing a respirator. This assessment should be done by experienced safety personnel or industrial hygienists.
How Do Respirators Work?
Respirators work by either filtering particles from the air, chemically cleaning (purifying) the air or by supplying clean air from an outside source. There are many different makes and models of respirators which are available from many different manufacturers, but they all fit into four basic categories: particulate respirators, chemical cartridge/gas mask respirators, powered air purifying respirators (PAPR) and self-contained breathing apparatus (SCBA).
Particulate respirators are the most common, simplest and least expensive and also offer the least amount of protection to the worker. This type of respirator includes half- and full-face piece cartridge respirators and filtering face pieces (dust masks). If you don’t already know, an N-95, N-100 and other dust masks are considered respirators by OSHA and the use of them by employees is subject to the requirements of Respiratory Protection Standard (1910.134), including fit testing. If respirators are not required to be worn due to exposure levels being below the PEL and are being used on a voluntary basis then compliance is simpler, but 1910.134 still includes some requirements that must be met before permitting their use in the workplace.
Chemical cartridge/gas masks respirators are half- and full-face piece air-purifying respirators equipped with the correct replaceable cartridge or canister filter. They are only effective when used with the right type of filter designed to remove the specific hazardous vapor or gas. Selecting the proper filter can be complicated. Some filters are available to protect against more than one substance, but there is no all-in-one filter that protects against all hazards. The filters are color coded to help ensure use of the right filter cartridge.
Powered air-purifying respirators (PAPRs) use a fan to draw air through the filter to the user. They are easier to breathe through, but they require a charged battery pack to ensure they work properly. There are several different types of PAPRs. Some use a half- or full-face piece that forms a tight seal to the wearer’s face and others use a hood or helmet which form a loose seal around the wearer’s face, neck or shoulders. The fan blows air into the hood or helmet creating a positive pressure to keep contaminants from entering the breathing zone. Similar to particulate and chemical respirators, PAPRs are not suitable for use in environments that are oxygen deficient.
The self-contained breathing or air-supplied breathing apparatus is commonly used by firefighters and workers who must enter into areas that are immediately dangerous to life and health. These use air supplied from their own air tank carried by the wearer or an external air supply such as a portable air tank or breathing air compressor. These respirators are the only type of respirator that may be used in oxygen-deficient atmospheres. Except for when used with an air compressor or cascaded air bottles, these respirators have a limited air supply. Special training is necessary to know how to use and maintain these types of respirators.
OSHA Requirements for Respirator Use
Once it has been determined that respirators are necessary to protect employees from potential respiratory hazards, the employer must develop and implement a written respiratory protection program which meets the requirements set forth in 1910.134. As explained above, there are different types of respirators and the employer will need to determine which type(s) of respirators their employees may have to use. To answer a question that is frequently asked by construction employers, requiring employees to use dust masks qualifies for the need to implement a respiratory protection program.
All respirator programs must be specific to the type of work and exposures that workers will encounter. The program must be administered by a person(s) who is trained and knowledgeable about the potential respiratory hazards and the type of respirators that may be used to control worker exposure.
The employer must include the following in the written respiratory protection program:
Procedures for selecting respirators for use in the workplace. These procedures must be based on the general use conditions, potential hazards and expected levels of exposure, oxygen concentration, potential for eye irritation and other environmental factors.
Medical evaluations of employees required to use respirators. Starting with a medical evaluation questionnaire included in Appendix C of the standard, the employees’ suitability to wear a respirator must be determined by a physician or licensed healthcare professional (PLHCP).
Fit-testing procedures for tight-fitting respirators, including dust masks. Before an employee is required to use any respirator that requires a tight-seal, the employee must be fit-tested with the same make, model, style and size of respirator that will be used. Note: Fit-testing dust masks is not an easy task and most safety professionals will tell you it is not possible. However, manufacturers like 3M have established procedures for fit-testing their products, which are available from their distributors or online.
Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations. Procedures will have to be established for the proper use of respirators. For example, a face piece seal. Many employees will have to be instructed to be clean shaven on areas of their face where the respirator seal will rest. Beards, stubble, mustaches and sideburns will prevent a tight seal. Using respirators with eye-glasses will require a procedure. A procedure will also have to be established for performing a user seal check.
Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding and maintaining respirators. Unless respirators are disposable, procedures will have to be established for inspecting and maintaining respirators to ensure respirators remain in safe and useable condition.
Procedures to ensure adequate air quality, quantity and flow of breathing air for atmosphere-supplying respirators. This requirement is specific to the use of self-contained and air-supplied respirators which are not in common use by construction personnel except in extreme situations.
Training of employees in the respiratory hazards to which they could be exposed.
Training of employees in the proper use of respirators. Using a respirator may seem simple enough, but there is a right way and wrong way to don and remove a respirator. Respirators have a limited use which workers must know and understand. Training to ensure No. 5 is met is also necessary. Training must be performed at least annually.
Procedures for regularly evaluating the effectiveness of the program. The employer must conduct evaluations to ensure the program is properly implemented and that employees are following the established procedures.
On sites where respirator use is not required, the employer may provide respirators or permit employees to use their own. If the employer does permit the voluntary use of respirators the employer must provide the employee with a copy of Appendix D — Information for Employees Using Respirators When Not Required, which provides basic instructions and warning for safe respirator use. In addition, the employer must establish that the employee is medically fit to wear a respirator and that the respirator is cleaned, stored and maintained so it does not present a health hazard. There is one exception: The employer does not have to include in a written program those employees whose only use of respirators involves the voluntary use of filtering face pieces (dust masks).
As you can see, there is more to requiring workers to wear respirators than just handing them out. Therefore, it is very important for construction employers to understand that the OSHA Respiratory Protection Standard — 1910.134 does apply to construction worksites.
For more information about complying with the respiratory protection requirements, respirator selection, medical evaluations, fit testing and more, visit OSHA’s website at www.osha.gov/SLTC/respiratoryprotection/index.html.
George Kennedy is NUCA Vice President of Safety.