Respirator Protection Program
February 15, 2000
This written program describes the UW - Stout program for respiratory
protection in accordance with Wisconsin Administrative Code, Commerce 32, and
the federal OSHA regulations codified in 29 CFR 1910.134. This
program is administered by the program administrator, Dean Sankey, who may be
contacted at Safety & Risk Management Services department in the University
Services building. Copies of this program are available from the
program administrator and shall be maintained in each respirator use area.
Supplied air respirators are not used. Air-purifying
respirators equipped with High Efficiency Particulate Air (HEPA) Filters shall
be used for all work with the potential to generate airborne asbestos
fibers. These respirators shall be NIOSH-certified in accordance with
NIOSH 42 CFR 84 as N100, R100, or P100 filters. All asbestos work shall
be performed in accordance with pertinent sections of 29 CFR 1910.1001.
Contaminant
Concentration Determination
Air-purifying respirators equipped with appropriate
cartridges are used for the following areas and tasks where air-monitoring has
indicated their appropriateness:
1. Greenhouses
and grounds while spraying pesticides;
2. Asbestos
repair or removal.
Air-monitoring shall be conducted by the Safety & Risk
Management Services department using American Industrial Hygiene Association
approved techniques for personal monitoring. Estimated exposures in
excess of published OSHA ceiling levels (C) or time-weighted average
permissible exposure limits (PEL) require the implementation of this respirator
protection program. Documentation of these levels shall also trigger an
engineering control investigation to determine the feasibility of reducing
contaminant concentrations below those levels requiring respirator use. A
statement regarding the conclusions reached by this engineering study shall be
included in Appendix I documentation.
Appendix I contains documentation of contaminant levels in
the above areas as determined by personal air-monitoring conducted during
"typical" tasks representative of work done in that area. This
air-monitoring shall be repeated if the materials used or the tasks done change
in any substantive way. The area employee and supervisor have the
responsibility to notify the program administrator of any such change.
Documentation of
contaminant levels below OSHA ceiling or PEL levels will also be retained in
Appendix I; such documentation is required to verify the appropriateness of any voluntary respirator use.
Respirator
Selection
The program administrator shall choose appropriate, NIOSH
certified respirator cartridge types taking into account the following
criteria:
1. Chemical
identity and concentration of air contaminant;
2. Recommendations
in the current NIOSH "Pocket Guide to Chemical Hazards;"
3. Recommendations
of pertinent, current MSDS for the material in use.
No air-purifying respirator will be chosen if air-monitoring
and/or estimates of concentration indicate that Immediately Dangerous to Life
or Health (IDLH) concentrations are or are likely to be present. Ambient
air concentrations of oxygen below 19.5% shall be considered
IDLH.
In so far as possible, all respirators chosen shall be
equipped with an end-of-service-life indicator (ESLI). If no ESLI
equipped respirator is available, a change schedule shall be developed by the
program administrator based on contaminant concentrations, contaminant warning
properties, and manufacturers data to ensure that the respirator will be
changed prior to the end of its service life.
The respirator cartridge type chosen, and any pertinent
change schedule, shall be documented in Appendix I in conjunction with the
air-monitoring data.
Medical
Evaluations
A medical evaluation shall be performed on each potential
respirator user. The evaluation must certify that the employee is
medically fit for respirator use prior to the employee's fit test and actual
use of any respirator. The medical evaluation will be performed by a
physician or other licensed health care professional (PLHCP) described here as
the Occupational Medicine Physician at Luther Midelfort. The initial
examination shall use the questionnaire in Appendix II. This
questionnaire can be filled out and sealed in an envelope by the employee at UW
- Stout for transmittal to the Occupational Medicine Physician at Luther
Midelfort in a manner to assure employee confidentiality. Follow-up
medical examinations are required for positive responses to questions 1 through
8 or upon the recommendation of the PLHCP. All medical evaluation
requirements shall be fulfilled during hours that the employee is in pay
status.
Additional medical evaluations shall be provided if:
1. An
employee reports medical signs or symptoms related to ability to use a
respirator;
2. Any
change in workplace conditions occurs which might substantially increase the
physiological burden of respirator use;
3. The
PLHCP, supervisor, or program administrator indicates a need for reevaluation;
or
4. Any
information from the respiratory program, such as observations made during
fit-testing or program evaluation, indicates a need for employee reevaluation.
The PLHCP shall be provided with the following information
prior to the medical evaluation:
1. A
copy of this written program;
2. A
copy of the current 29 CFR 1910.134 regulations;
3. The
type and weight of the respirator to be used;
4. The
duration and frequency of respirator use;
5. The
expected physical work effort;
6. Any
additional protective clothing and equipment to be worn; and
7. An
estimate of the temperature and humidity extremes which may be encountered.
The PLHCP shall provide Dean Sankey at UW - Stout with a
written recommendation regarding the employees ability to use a
respirator. This recommendation shall contain:
1. A
statement as to the employees medical ability to use a respirator;
2. Any
limitations regarding respirator use;
3. Any
need for follow-up medical evaluations;
4. Recommended
frequency, if any, for follow-up medical evaluations; and
5. A
statement that the PLHCP has provided the employee with a copy of the written
recommendation.
The written medical evaluation shall be confidentially
maintained and made available in accordance with OSHA requirements codified in
29 CFR 1910.1020.
Fit Testing
Following medical evaluation resulting in a positive
recommendation that an employee is medically fit for respirator use, each
employee shall be fit tested prior to initial use and at least annually
thereafter. Each fit test for each employee shall be documented in
Appendix III of this program. All fit tests shall offer the employee
choices of respirator face pieces to maximize the effectiveness of the face seal.
The fit test shall be conducted according to procedures
described in Appendix III; qualitative fit tests will be the standard
methodology following documentation that the required fit factor is less than
100. This documentation shall be described in relation to the data
defining contaminant concentrations pertinent to the anticipated use of the
respirator.
Follow up fit tests shall be conducted whenever the
employee, the PLHCP, supervisor, or program administrator reports visual
observations or any other indication which could affect respirator fit.
A satisfactory fit test shall result in the chosen
respirator face piece being assigned to the specific employee for their
individual and exclusive use. Shared negative pressure respirator use is not
permitted under the requirements of this program.
Respirator Use
Standard Operating Procedures must be followed for all
required respirator use according to this program. These procedures are
specific to each respirator use area and are documented in each area.
General standard operating procedures include:
1. Any
change in materials or procedures requires additional contaminant concentration
air-monitoring;
2. Required
respirator use under this program requires the employee to have no facial hair,
corrective glasses, goggles, or other PPE which interferes with the sealing
surface of the face piece or valve function;
3. The
supervisor to ensure that employees perform a user seal check each time the
respirator is used; seal check procedures are documented in Appendix IV of this
program.
Continuing Program
Evaluation
Supervisors are required to maintain appropriate
surveillance of the respirator use area to determine and document the ongoing
effectiveness of the program. This evaluation shall include consultation
with employees to determine their views on program effectiveness.
Surveillance shall include observations to ensure:
1. Respirators
must be inspected prior to each use and during cleaning; inspections shall
include:
A. Function
and tightness of connections;
B. Condition
of face piece, straps, valves, connecting tubes, cartridges, canisters or
filters;
C. Pliability
and signs of deterioration in elastomeric parts;
2. Any
change in conditions or contaminant concentrations which require reevaluation
of any aspect of this program;
3. Proper
respirator fit, use, and maintenance are maintained;
4. That
employees leave the use area:
A.
To wash faces and respirator face pieces as
necessary to prevent eye or skin irritation;
B.
If they detect respirator breakthrough, changes in
breathing resistance, or leakage;
C.
To replace respirator, filter, cartridge, or
canister elements;
5. That
respirators must be repaired or replaced before returning to the use area in
the event of 2.B. above.
6. Any
required repairs shall be made using only respirator manufacturer's
NIOSH-approved parts and be done only by appropriately trained persons;
7. That
respirators are cleaned, disinfected, and stored properly following each use.
Program evaluations shall be conducted periodically as
necessary to maintain an effective program. Documentation of program
evaluations shall be maintained in Appendix V of this program.
Respirator
Cleaning, Disinfecting, and Storage
Respirators must be cleaned and disinfected as often as
necessary using the procedures described in Appendix VI of this program.
All respirators used in fit testing shall be cleaned and disinfected using
Appendix VI procedures after each use and prior to fit testing another
employee.
Respirators must be stored in a clean and sanitary fashion
to prevent their being damaged or contaminated. Storage conditions must
ensure that the face piece and exhalation valve are not deformed.
Training and
Information
The program administrator is required to provide effective
training prior to any respirator use, annually, and more often if judged necessary
by the program evaluation. This training shall be comprehensive,
understandable, and result in each employee being able to demonstrate knowledge
of:
1. Why
respirator use is necessary;
2. How
improper fit, usage, or maintenance can compromise the protective effect;
3. Limitations
and capabilities of the respirator;
4. Effective
actions in the event of emergency or respirator malfunction situations;
5. How
to inspect, put on, remove, use, and check seals of respirator;
6. Proper
procedures for maintenance and storage of respirator;
7. Medical
signs and symptoms which might limit or prevent effective use of respirator;
8. General
requirements of this program
Respirator.protection.pln.doc