Safety Tidbit #30 – Do you really need a respirator?
I hate going into a workplace,
finding workers wearing respirators only to find the program sorely
lacking. A respirator is a form of
personal protective equipment; you know the last line of defense against some
dastardly airborne agent of destruction.
However, please keep in mind that a respirator is also a hazard. It places an increased burden on the
respiratory system.
The respiratory protection standard (1910.134) is quite easy to
audit. We make sure they have a written
program [1910.134(c)(1)], medical clearance [1910.134(e)], fit-testing
[1910.134(f)], and training [1910.134(k)].
We should also evaluate the storage and care of the respirators [1910.134(h)(1)
and (h)(2)]. Sometimes we may even check
their filter cartridge change-out schedule when they have organic chemicals as
their contaminant. We may be really
exotic and validate their breathing air [1910.134(i)(1)(i)] when they use
supplied-air respirators.
Or, did we even think to consult
the views of worker required to use respirators? [1910.134(l)(2)] We need to
ask them about the program’s effectiveness, the respirator fit (ability to use
the respirator without interfering with effective workplace performance),
respirator selection, care, and maintenance.
Sure, we can do an audit and get
our number of hazards found during the visit. The Respiratory Protection
Standard says that the employer will evaluate the risk to ensure proper
selection and level of protection. [1910.134(d)] However, how often do we take
a step back and validate the fundamental need for the respirator? Here I quote
from the first paragraph of the Standard [1910.134(a)(1)]:
“In the control of those occupational
diseases caused by breathing air contaminated with harmful dust, fogs, fumes,
mists, gases, smokes, sprays, or vapors, the primary objective shall be to
prevent atmospheric contamination. This shall be accomplished as far as
feasible by accepted engineering control measures (for example, enclosure or
confinement of the operation, general and local ventilation, and substitution
of less toxic materials). When effective engineering controls are not feasible,
or while they are being instituted, appropriate respirators shall be used
pursuant to this section.”
And then the second paragraph speaks to the right
respirator:
“A respirator shall be provided to each
employee when such equipment is necessary to protect the health of such
employee. The employer shall provide the respirators which are applicable and
suitable for the purpose intended. The employer shall be responsible for the
establishment and maintenance of a respiratory protection program, which shall
include the requirements outlined in paragraph (c) of this section. The program
shall cover each employee required by this section to use a respirator.”
So, I submit that we must always question the necessity of a
respirator, and I close the way I began: respirators are not just personal
protective equipment, they are also a hazard. We should not introduce a new risk
into the workplace if within our power to prevent it. Industrial Hygienists, we must always:
Anticipate – Identify – Quantify – Control.
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