1.0 BACKGROUND T.O.C.
This Program is promulgated pursuant to regulatory requirements of the Occupational Safety and Health Administration (OSHA). See 29 CFR Part 1910.134.
2.0 POLICY T.O.C.
It is the policy of Emory University to provide all employees a safe and healthy work environment reasonably free of recognized physical, chemical, biological, and other occupational hazards. Utilizing the proper facilities and equipment; training persons in high-risk situations; and following applicable standards and regulations accomplish this. The Occupational Safety and Health Administration (OSHA) respiratory protection standard, (29 CFR Part 1910.134) serves as the main reference for this Respiratory Protection Program to prevent and/or minimize occupational diseases caused by air contaminated with harmful biological, radiological agents or dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors. The Schools, departments, and divisions of Emory University fall under this Program. Emory will make reasonable efforts to control contaminants through accepted engineering control measures (i.e., enclosure or confinement of the operation, general and local ventilation, and substitution of less toxic materials), but in situations in which effective engineering controls are not feasible, or while in emergency situations, appropriate respirators shall be used.
This program does not apply to contractors hired by the University, as they are responsible for providing their own respiratory protection programs and respiratory protective equipment.
3.0 REGULATORY REQUIREMENTS T.O.C.
The OSHA standard for Respiratory Protection is contained in Subpart I of OSHA’s general industry standard. The original standards were adopted in 1971 from established Federal standards and national consensus standards. The effective date for the revised standard is October 5, 1998.
Per the Respiratory Protection Standard (29 CFR Part 1910.134):
3.1 THE RESPIRATORY PROTECTION PROGRAM T.O.C.
The Respirator Protection Program set forth herein is based on and incorporates by reference the regulations set forth at 29 CFR 1910.134, as well as any amendments that may be made to such regulations from time to time. Copies of these regulations are attached hereto. In the event of any discrepancy between the regulations and any other part of this program, the stricter provisions shall control. In accordance with OSHA regulations the Respiratory Protection Program described herein includes the following provisions:
Emory University and the Emory System of Healthcare shall be identified as the “employer.” The Emory University Environmental Health and Safety Office (EHSO) shall be responsible for providing guidance to Directors, Deans, Department Chairpersons, and other requesting employees with any applicable guidance and administration necessary to carry out and maintain individual management protocols for this program. Mr. Lee Alderman, Director of the EHSO, the Program administrating entity, shall appoint the Program Coordinator(s) from within EHSO and shall be assigned to coordinate with various departments, divisions, and units of the University. Emory Hospital and Clinics shall appoint Program Coordinators in coordination with the Program Administrator. The Program Coordinator(s) shall ensure that any and all personal protective equipment specified in this Program will be provided to employees at no cost when such equipment is necessary to protect the health of the employee during job responsibilities. The EHSO Program Administrator and the various Program Coordinators shall provide the respirators applicable and suitable for the purpose intended and shall maintain a log of said users. The Program Coordinators shall also be responsible for the implementation and maintenance of the Respiratory Protection Program set forth herein which includes the requirements outlined in Section 6.0 of this document.
EHSO through its Program Coordinators shall provide appropriate surveillance of work area conditions and worker exposure to respiratory hazards with the use of good industrial hygiene practices. In situations in which respiratory protection is required, Program Coordinators shall work to ensure a proper match between respirator and wearer. The Program Coordinator will instruct and train the wearer on performing the positive and/or negative-pressure check before entering and during exposure to a hazardous atmosphere. The employee shall test the respirator face piece using the negative/positive fit checks each time it is worn. Qualitative fit tests will use irritant fumes or other testing procedures outlined in this Program. Quantitative fit tests will use either fit test chamber or a TSI Portacount Plus as outlined herein. Qualitative and Quantitative fit testing procedures are included in the Appendices of this document.
Program Coordinators will provide inspections to ensure respirators selected for the job are being used and are in good condition. Periodic monitoring of respiratory protection being used shall include:
The health care providers at the Emory Clinic or a private contractor will be used for medical evaluation, questionnaire review, and surveillance. All personnel who may be required to wear respiratory protective equipment in the completion of their assigned tasks will be required to undergo a review of health status at least annually.
*Note: The OSHA respirator standard and the NIOSH certification standard work together. The OSHA standard requires selection of NIOSH-certified respirators and use as specified by the conditions of NIOSH-certification. The OSHA standard is being published during the transition from respirators certified under the old NIOSH 30 CFR Part 11 certification procedures to those certified under the new NIOSH 42 CFR Part 84 procedures. The OSHA standard accommodates respirator selection under either NIOSH standard. At the present time N95 (particulate filtering) respirators are classified under the NIOSH 42 CFR Part 84 ruling. Chemical cartridges will soon be under this standard. Respirators certified by NIOSH under 42 CFR Part 84 would be acceptable to OSHA for protection against occupational exposure to TB.
4.2 Supervisor/ Principal Investigators T.O.C.
Each department, division or unit of the University in which respirators are used will assign a supervisor/ principal investigator to serve as a point of contact with the Program Coordinators/EHSO. These designated Principle Investigators/Supervisors will receive appropriate training from EHSO regarding these responsibilities. Supervisors/Principle Investigators will ensure each employee under his or her supervision using a respirator has received appropriate training in its use and has completed the medical evaluation/questionnaire. Supervisors/Principle Investigators will ensure the availability of appropriate respirators and accessories, provide adequate storage facilities, and encourage proper respirator equipment maintenance. Supervisors/Principle Investigators must be aware of tasks requiring the use of respiratory protection and ensure employees engaged in such work, use appropriate respirators at the appropriate times.
4.3 Employee: T.O.C.
The employee shall be responsible for safe and appropriate use of any respiratory protection equipment provided in accordance with the instructions and training received through application of this document. Each employee should also:
*NOTE: Fit testing shall not be conducted if there is any hair growth between the skin and the face piece-sealing surface, such as stubble, beard, mustache or sideburns crossing the respirator-sealing surface. Additionally, fit testing shall not be performed unless the physicians written approval accompanies the individual to be tested. Refer to attached OSHA Standards Interpretation and Compliance Letters in Appendices.
5.05.0 PROGRAM ADMINISTRATION T.O.C.
The Respirator Program Administrator, EHSO, will develop and distribute this Respiratory Protection Program and provide technical assistance in the interpretation and application of the OSHA requirements. Deans, Directors, and Department Chairpersons, Principal Investigators and Supervisors of Emory University shall also ensure the required safety practices and procedures are carried out in their areas of responsibility. The Respiratory Protection Program applies to all employees, medical residents, interns, and any other short term or non-Emory person who may have respiratory exposure to hazardous substances in any of the various university environments.
6.0 PROGRAM COMPONENTS T.O.C.
The following are detailed written procedures for respirator selection and use. The EHSO has established these methods to ensure this respirator program remains effective.
6.1 Written Standard Operating Procedures T.O.C.
The written standard operating procedure (SOP) incorporates the OSHA 29 CFR Part 1910.134 and any amendments that may be made there to from time to time. The Program Administrator shall develop detailed written standard operating procedures governing the selection and use of respirators, using the NIOSH Respirator Decision Logic and most current ANSI standard for respiratory protection as guidelines. Other recognized authorities will be consulted if there is additional assistance needed regarding proper selection and use.
6.2 Medical Review and Evaluation T.O.C.
Using a respirator may place a physiological burden on employees depending on the type of respirator worn, the job and the workplace conditions in which the respirator is used, and the medical status of the employee. Furthermore, some regulatory standards for specific substances (i.e. radiological, biological) may contain requirements for medical examinations. Should the workplace hazard evaluation determine a specific operation or performance of a person’s job exposing them to a respiratory hazard. Emory, at no cost to the employee, shall have a physician or other licensed health care professional (PLHCP) designated by Emory determine what health and physical conditions are pertinent to the employee and review the respirator wearers medical status as per OSHA regulations 1910.134(e). Those individuals who will be issued a cartridge type respirator or are required to aid in emergency response activity shall have their medical status reviewed annually through medical examination. Per OSHA regulations the medical questionnaire attached hereto shall be used to assist in the evaluation of an employee’s ability to wear a respirator in certain cases. The implementation of the questionnaire and/or examination shall be administered confidentially during the employee’s normal working hours or at a time and place convenient to the employee. The medical questionnaire shall be administered in a manner that ensures the employee understands its content.
Should the reviewing physician or other licensed health care professional identify the need for further examination, medical tests pertinent to the respiratory hazards the worker may encounter shall be performed to obtain baseline data to assess future physiological changes in the respirator wearer. Results of the examinations should be compared with those of the baseline examinations and/or previous periodic examinations to determine whether the respirators used are adequate and to reevaluate fitness for duty. When necessary, a copy of the appropriate substance specific standard will be provided to the physician for reference to assist in the examination.
PLHCP shall receive a copy of this program including a copy of the OSHA Respirator Standard. Emory University will ensure previous evaluations are transferred to a new PLHCP in the event of a change. Employee employment medical records, medical fit testing releases, fit testing results, and annual training records shall be maintained by departmental Directors or another designated entity. Employees will be permitted to evaluate this information at any time and be informed on annual basis of where these records are located and the employee’s rights for access in accordance with 29CFR 1910.1020. Upon employee’s severance of employment, their records shall be maintained for the period of at least 30 years or as specified in applicable standards.
The following are guidelines for proper implementation and scheduling of medical evaluations:
Medical evaluations shall be required for all individuals prior to fit testing for respiratory protection in accordance with Section (e) of the standard. Those individuals who do not obtain a medical evaluation and written approval from a PLHCP prior to fit testing shall not be allowed to wear respiratory protection and shall not be permitted to enter work environments where respiratory protection is required or worn as a precautionary measure.
6.3 Respirator Selection on Basis of Hazards T.O.C.
Respirators will be selected on the basis of hazards to which the worker is exposed. As part of this selection process an assessment of worker exposure in conjunction with manufacturer’s data will be used to determine correctness and develop filter/canister change schedule. All selections will be made by the Program Administrator or individual Coordinators in accordance with Section (d) of the standard. Only NIOSH-certified respirators shall be selected and used. Respiratory protection shall be authorized and issued to the following personnel:
Respirators for use in areas where biohazards are used or stored shall be selected based on a review of the laboratory procedures, protocols, biohazardous agents proposed for use, etc. The Biosafety Officer in EHSO will conduct a risk assessment and determine the appropriate Biosafety Level for the laboratory and the corresponding level of personal protective equipment required.
6.4 Types of Respirators T.O.C.
These respirators provide breathing air independent of the environment. Such respirators are to be used when the contaminant has insufficient odor, taste or irritating warning properties, or when the contaminant is of such a high concentration or toxicity that an air-purifying respirator is inadequate.
These respirators remove air contaminants by filtering, absorbing, adsorbing, or chemically reacting with the contaminants as they pass through the respirator filter, canister or cartridge. This respirator is “only” to be used only where adequate oxygen (19.5 to 23.5 percent by volume) is available. Air-purifying respirators can be classified as follows:
The EHSO shall ensure supplied-air respirators are supplied for environments where oxygen is deficient or the employer cannot identify or reasonably estimate the employee’s exposure. The employer shall consider these IDLH environments. Respirators provided for the escape from or entrance into IDLH atmospheres shall be NIOSH certified for escape from the atmosphere where they will be used.
All oxygen deficient atmospheres shall be considered IDLH. Personnel shall not be asked to enter work environments where there is a suspect or potential IDLH condition until the employer has evaluated this condition.
*NOTE: The area Program Coordinator shall be responsible for maintaining the recommended levels of training and maintenance associated with all supplied-air respirators.
Permitted supplied-air respirators, also called air-line respirators are classified as follows:
This respirator maintains a continuous positive pressure within the face piece, thus preventing leakage into the face piece.
This respirator maintains a continuous flow of air through the face piece and prevents leakage into the face piece.
This type of respirator allows the user complete independence from a fixed source of air and offers the greatest degree of protection, but is also the most complex. Training and practice in its use and maintenance is essential. This type of device will be used in IDLH situations always.
6.5 Instructions and Training of User for Hazard T.O.C.
The user shall be instructed and trained in the proper use of respirators and their limitations. Both supervisors and workers will be so instructed by members of EHSO or other trained individuals as necessary. Each respirator wearer will receive fitting instructions, have an opportunity to select and handle the respirator, have it fitted properly, test its face-to-face seal, and wear it in a test atmosphere. Supervisors and employees will observe demonstrations of how to wear the respirator, adjust it, and determine if it fits properly.
Wearing of respirators shall not be allowed when conditions prevent a good face seal. Such conditions may be facial anomalies: beard, sideburns, and skullcap projecting under the face and/or temple pieces on glasses. Respirator training will be properly documented and include the manufacturer, type and model of a respirator for each individual.
6.6 Cleaning, Disinfection, and Storage T.O.C.
Respirators will be regularly cleaned and disinfected. Those issued for the exclusive use of one worker will be cleaned after each day’s use or more often if necessary. Those used by more than one worker will be thoroughly cleaned and disinfected after each use. Worn or deteriorated parts will be replaced. Respirators for emergency use such as self-contained devices will be thoroughly inspected at least once a month and after each use.
The manufacturer’s instructions should be followed for cleaning and disinfecting respirators. Any good detergent may be used to clean respirator face pieces. Prepackage cleaner and sanitizer solutions can be purchased from the respirator manufacturer. If permitted by the manufacturer’s instructions, an alternative to the prepackaged solution would be to wash the respirators in a mild detergent (soap) followed by a clean water rinse. Disinfection is not absolutely necessary if the same worker reuses the respirators. Where individual respirators are not issued, disinfection is required. Reliable, effective disinfectants may be made from readily available household solution, including:
To avoid damaging the rubber and plastic in the respirator face pieces, the cleaner and disinfectant temperatures should not exceed a maximum temperature of 140 degrees Fahrenheit to ensure adequate cleaning.
The cleaned and disinfected respirators should be rinsed thoroughly in clean water between the temperatures of 120-140 degrees Fahrenheit for no less than 1-2 minutes to remove all traces of detergent, cleaner, sanitizer, and disinfectant. This process is very important to prevent potential skin irritation. The respirators should be allowed to dry by themselves on a clean surface and away from potential sources of contamination. Once clean and dried, the respirator face pieces should be reassembled and inspected. An important thing to look for during reassembly and inspection is detergent or soap residue left by inadequate rinsing that would cause cracking or a deformed face, valves and/or straps which can be sources of leakage or sticking. When feasible, respirators will be assigned to each individual worker for their exclusive use.
NOTE: N95 respirators shall be discarded when excessive resistance, physical damage, contamination with blood or body fluids or any other condition renders the respirator unsuitable for use
According to OSHA standards and good health and safety practices storage of respiratory protection equipment should be done to protect against:
It is strongly recommended that freshly cleaned respirators be placed in heat-sealed or reusable plastic bags (such as zip-lock bags®) until reissue or reuse. They should be stored in a clean, dry location away from direct sunlight. They should be stored in a single layer with the face and exhalation valve in a more or less normal position to prevent the rubber or plastic from taking a permanent distorted “shape.”
Air-purifying respirators available for non-routine or emergency use should be stored in individual compartments of a cabinet. The storage cabinet should be accessible away from potential sources of contamination and all workers should be made aware of its location. This type of storage should be encouraged for routinely used respirators if it does not interfere with the normal work routine. As with air-purifying respirators, the storage location of SCBA’s should be well known, clearly marked, and in an area remaining uncontaminated.
Routinely used respirators may be stored in a variety of ways if they are protected against the substances and conditions listed at the beginning of this section. When a respirator is not in use, it should be stored in a sealable plastic bag and dedicated for storage in a secure area.
6.7 Inspection and Warning Signs of Respirator Failure T.O.C.
All respirators used under permanent or temporary assignment shall be inspected prior to each donning by the assigned employee and during cleaning. The employee shall be responsible for inspection of the following points:
SCBA’s shall be inspected monthly. Air and oxygen cylinders shall be maintained in a fully charged state and shall be recharged when the pressure falls to 90% of the manufacturer’s recommended pressure level. The employer will also determine that the regulator and warning devices function properly.
If repairs are needed contact your immediate supervisor who in turn should contact one of the designated Program Coordinators. Repair protocols will be implemented in accordance with Section (h)(4) Repairs of the standard.
Warning Signs of Respirator Failure
When breathing difficulty is encountered with a filter respirator (due to partial clogging with increased resistance), the filter(s) must be replaced. Used filter cartridges and disposable respirators must be properly discarded.
When using a gas or vapor respirator (chemical cartridge or canister) any of the warning properties (e.g., odor, taste, eye irritation, or respiratory irritation) occur or end of life service indicator (ESLI) expires, promptly leave the area and check for the following:
If no discrepancies are observed, replace the cartridge or canister. If any of the warning properties appear again, the concentration of the contaminants may have exceeded the cartridge or canister design specifications. When this occurs, an airline respirator or SCBA is required.
The Occupational Safety and Health Administration is in the process of developing guidance materials for possible use by employers in complying with the Respiratory Protection Standard (29 CFR 1910.134). Section (d) 3(iii) B of the standard requires the employer determine a respirator cartridge change-put schedule from objective information or date which will ensure that respirator cartridges are changed before the end of their service life. The currently acceptable methods by which the employer can estimate the cartridge service life include “Rule of Thumb”, “mathematical Models”, and Experimental Testing”. In situations where OSHA has promulgated standard specific requirements for filter cartridge replacement these rules and schedules shall take precedence.
The following change our schedules will apply for categories of exposure:
FORMALDEHYDE:
The OSHA Standard for Formaldehyde, 29 CFR 1910.148, Section (g)(2)(ii)(A), requires that the cartridges be replaced after three (3) hours of use or at the end of the work shift where the employee is required to wear such respiratory protection due to ambient levels of formaldehyde exceeding the OSHA PEL as determined by the EHSO. This schedule shall be adhered to unless the chemical cartridges contain a NIOSH approved end-of-service-life indicator (ESLI) specific for formaldehyde to show when breakthrough occurs.
OTHER ORGANIC CHEMICALS (RULE OF THUMB METHOD):
If the chemical’s boiling point is > 70 degrees Celsius and the concentration is less than 200 ppm chemical cartridges suitable for the type of exposure shall be replaced after a service life of no more than 8 hours at a normal work rate. Moderate to heavy work rates will require that the service life be reduced to a 4-hour period of use. Concentrations measured below 20 ppm shall be replaced after a service life of 40 hours of use at a normal work rate and 20 hours of use at a moderate to heavy work rate. These service life replacement schedules only apply to work in areas with a humidity level <85%. Excess humidity acts to further reduce the effectiveness and useful life of the absorbent material. Refer to the EHSO for work specific determinations of humidity levels.
PARTICULATE:
The canister or cartridges of air-purifying respirators equipped with High Efficiency Particulate Air (HEPA) filters are intended to be used until filter resistance precludes further use due to excessive breathing difficulty causing elevated heart rate, overheating, signs of lightheadedness, or similar symptoms resulting from pulmonary stress. A maximum use time for HEPA filters shall be no longer than six (6) months. Six months maximum replacement schedule is designed to eliminate undetectable filter degradation, leaks, or increased filter resistance undetected by the wearer. A new cartridge should immediately replace visible damage to the outer casing of the cartridge or the filter membrane.
IDENTIFICATION AND TRACKING:
It is the responsibility of the supervisor to inform all employees who fall within this program of the end-of-service-life cartridge replacement schedule and to have available a suitable number of replacement cartridges applicable for the chemical or physical agents present in the work environment. The supervisor shall instruct the employer on marking the respirator cartridges in a way which helps in determining end-of-service-life. This may be either a work-based schedule (end of shift, breaks, etc.) or based on a calendar date, which is written on the respirator cartridge in indelible ink.
The canister or cartridges of air-purifying respirators are intended to be used until filter resistance precludes further use or the chemical sorbent is expended as signified ELSI or filter change schedule as determined by EHSO. Other properties which may also indicated cartridge/canister failure would be specific warning properties, e.g., odor, taste, etc. New canisters, cartridges or filters shall always be provided when a respirator is reissued. When in doubt about the previous use of the respirator, obtain a replacement canister or cartridge from immediate supervisor or Program Coordinators.
When using an airline respirator, leave the area immediately if the compressor failure alarm is activated or an air pressure drop is sensed. When using an SCBA, leave the area as soon as the air pressure alarm is activated.
Compressed breathing air shall meet the requirements for Type 1-Grade D breathing air as described in ANSI/CGA Commodity Specification for Air, G-7.1-1989.
6.8 Evaluation of Respirator Protection Program T.O.C.
Emory Respiratory Protection Program Coordinators shall be responsible for ensuring regular inspections and evaluations of the Program are performed to determine its continued effectiveness. The Program shall be evaluated at least annually with a revision of the written operating procedures if needed. A checklist shall be provided to all department supervisors with an outline of areas to be inspected on a regular basis. Examination of respirators being used or stored can be conducted by frequently consulting wearers about their acceptance of respirators, discomfort, resistance to breathing, fatigue, interference with vision and communication, restriction of movement, interference with job performance, and confidence in the respirators effectiveness.
The EHSO shall review the data generated during periodic inspections of respirator use, consultations with wearers, measurements of hazard levels in work areas, and medical surveillance of wearers to determine the effectiveness of the program. Any evidence of excessive exposure to hazards shall be followed up to determine why inadequate protection was provided and what actions should be taken to immediately remedy the problem.
The Respirator Program Coordinators shall provide the results of the written program evaluation to the EHSO Program Administrator for review.
6.9 Program Policies for Facial Hair T.O.C.
The issuance and fit testing of individuals shall not be conducted if there is any hair growth between the skin and the face sealing surface, such as stubble beard growth, beard, mustache or sideburns crossing the respirator sealing surface. (NOTE: Respirators shall not be altered in attempts to afford a proper face piece to face fit).
6.10 Voluntary Use of Respirators T.O.C.
Where a respirator is not required, an employer may provide respirators at the request of employees or permit employees to use their own respirators, if the employer determines that such respirator use will not in itself create a hazard. If the employer determines that any voluntary respirator use is permissible, the employer shall provide the respirator users with the information contained in Appendix D of OSHA Standard 1910.134.
6.11 Fit Testing for Tight Fitting Respirators T.O.C.
All employees using a negative or positive pressure tight-fitting face must pass an appropriate qualitative fit test or quantitative fit test. This includes all types of air-supplied, positive-pressure, powered air purifying, SCBA, etc. Positive-pressure respirators must be fit tested in negative-pressure mode. Refer to Appendix B of this program
Fit testing is required prior to initial use, whenever a different respirator face is used, and at least annually thereafter. An additional fit test is required whenever the employee reports, or the employer or PLHCP makes visual observations of, changes in the employee’s physical condition that could affect respirator fit (e.g., facial scarring, dental changes, cosmetic surgery, or an obvious change in body weight).
6.12 Emergency Use and IDLH Environments T.O.C.
The employer shall provide the following respirators for employee use in IDLH atmospheres: A full face pressure demand SCBA certified by NIOSH for a minimum service life of thirty minutes, or a combination full face pressure demand supplied-air respirator with auxiliary self-contained air supply.
The procedures for all IDLH atmospheres at Emory University will be in accordance with section (g)(3) of the standard. Emory will ensure that one employee or, when needed, more than one employee is located outside the IDLH atmosphere; visual, voice, or signal line communication is maintained between the employee in the IDLH atmosphere and the employee located outside the IDLH atmosphere; the employee located outside the IDLH atmosphere is trained and equipped to provide effective emergency rescue; the employer or designee is notified before the employee located outside the IDLH atmosphere enter the IDLH atmosphere to provide emergency rescue; the employer or designee authorized to do so by the employer, once notified, provides necessary assistance appropriate to the situation; employees located outside the IDLH atmosphere are equipped with proper respiratory protection for these atmospheres; and appropriate retrieval equipment for removing the employee(s) who enter(s) these atmospheres where retrieval equipment would contribute to the rescue of the employee(s).