Safety Tidbit 3.10 - Nine Elements of a Respirator Program

Safety Tidbit 3.10 – Nine Elements of a Respirator Program

References: OSHA Respirator Standard 1910.134

Danyluk, Q., Hon, C.-Y., Neudorf, M., Yassi, A., Bryce, E., Janssen, B., & Astrakianakis, G. (2011). Health Care Workers and Respiratory Protection: Is the User Seal Check a Surrogate for Respirator Fit-Testing? Journal of Occupational & Environmental Hygiene, 8(5), 267–270. https://doi.org/10.1080/15459624.2011.566016

Seems like lately my clients have had more than the usual curiosity with respirators. Most of my clients know that I don’t like respirators and, as a devoted IH, I try to reduce the need for respirators in every workplace I go into. Therefore, I figured I needed to take a step back and list the nine basic elements of a respirator program as defined by OSHA [1910.134(c)(1)]:

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 of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations

8.     Training of employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance

9.     Procedures for regularly evaluating the effectiveness of the program

Of course, the program is topped off with a “suitably trained” program administrator [1910.134(c)]. And, as I mention a couple of Safety Tidbits ago, for all tight-fitting respirators, the employer shall ensure that employees perform a user seal check each time they put on the respirator [1910.134(g)(1)(iii)].

An interesting side note, research has shown that even with a proper user respirator seal fit-check 25-30% of users fail a quantitative fit-test and 14-22% fail qualitative fit-testing. (Danyluk et al., 2011)  Seems like an awful lot of trouble to go through to still be unsure if workers are protected from the airborne hazard. Just saying…

Hope this was helpful and thanks for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have an interesting safety or health question please let me know.

Safety Tidbit 3.09 – Duty to have Fall Protection and Leading-Edge Work

Safety Tidbit 3.09 – Duty to have Fall Protection and Leading-Edge Work

Reference: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10757

I was headed to a store earlier this week. The store was in a strip mall in which each store had a little roof above the main entrance or the “porch” of the store. The top of the porch was about 10 feet high and jut out from the front wall about 3 feet. Above the roof of each store had the company sign or logo. I noticed a new store going in where another store had recently left and the construction company was busy taking down the old and putting up the new sign and making any repairs to the roof while they were up on top.

I’m sure you all know where I’m headed with this observation. Interestingly, the worker did have a harness on but was not tied off to anything. Of course, I stopped and asked the worker if she felt safe working up on the roof with a harness on but not secured to anything? She said there was nowhere to tie off and she was extra careful. I mentioned about OSHA’s requirements for fall protection in 1926.501(b)(1): “Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge which is 6 feet (1.8 m) or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems.” I reminded her that wearing a harness is only part of the personal fall arrest system.

She then commented that her boss told her if OSHA comes by that she was to explain to them that she is doing leading-edge work and it was infeasible to use the fall arrest system. I told her that even leading-edge work needs to have fall protection. If not in the form of guardrails, safety nets or personal fall arrest systems then the employer must establish a fall protection plan and implement it [1926.501(b)(2)(i)] unless the employer shows that it is in fact infeasible. I pointed to a scissor lift parked inside the store used for working on the ceiling as an alternative or the possibility of erecting a scaffold that would give protection. Not to mention the various commercially-available portable, temporary guardrail systems that can be bought or rented.

I explained that just because the means to be safe is not immediately known or available does not mean that it is infeasible to be safe. Proper planning on her boss’ part could have ensured her safety.

Hope this was helpful and thanks for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have an interesting safety or health question please let me know.

Safety Tidbit 3.08 – So you want to refinish your cabinets

Safety Tidbit 3.08 – So you want to refinish your cabinets

Reference: https://www.osha.gov/dsg/hazcom/whatishazcom.html

How many of you have refinished your kitchen cabinets or a piece of furniture? Wasn’t it a pain to strip off the old finish especially when covered with lacquer or polyurethane? You probably did what I did and go to your local hardware store or big box chain (e.g., Lowes or Home Depot) to get some stripper. Yup that’s what I did, but once I arrived at Lowes, I was surprised that there were quite a few types of paint removers to choose. So, the industrial hygienist in me began to inquire: Why so many? And What is the difference between them?

Some are in paste form and some in a liquid. Some say hazardous others say biodegradable. Being the novice, 
I asked the salesperson in the area for some help. She advised me that Formby’s was the “good” stuff and to stay away from the Citristrip™ that smells like oranges but doesn’t work as well and besides, Formby’s stripper is cheaper than Citristrip™. I prodded her a little and asked why does Formby’s work better than Citristrip™? Her response was disturbing: "Formby’s stripper works because it has some powerful chemical in it that the other one does not.” So now I changed my hat from novice to industrial hygienist and asked, Can I get more information about the two products and what is in them?  I think she knew she was had and tried to push me to her supervisor that she called for on her radio. 

Once the supervisor arrived I again asked for more information about the products such as the safety data sheet. The area supervisor pushed me to the customer service desk as “supposedly” all of the SDSs for any products sold are distributed there.  Unfortunately, I received the vacant stare when I asked for the SDS for each of the products I was considering using in my home. Just to keep the exercise going I offered, what happens if a commercial entity like a construction company comes in to buy the same items and asks for the SDS? That lit up the customer service desk’s light bulb above his head.  He shuffled me over to the commercial client desk on the other side of the store. He looked as relieved as the other two when they were able to hand me off to someone else. The client customer service representative was very confident as I asked my questions about the getting the SDSs for the products. He promptly gave me the www.NameofStore.com website and said I needed to go online, and all of the SDSs are there. Problem solved, right?

Well of course not, I got home to look up both items on the store’s website and could not find the SDS anywhere. So now my stubbornness kicks in, and I go to the manufacturers’ websites to get the SDSs. Although not particularly intuitive or easy to find after 15-20 minutes of searching on each of the products' sites I finally found what I was looking for. Moral of the story if your client is missing an SDS see if they have a systematic approach to get or find the SDS from the manufacturer or distributor. Unfortunately, with the manufacturers only having to provide the information electronically via an internet address very little has been done to ensure the address is accurate and actually leads the client to the information.

Hope this was helpful and thanks for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have an interesting safety or health question please let me know.

Safety Tidbit 3.07 – Retesting Respirator Users

Safety Tidbit 3.07 – Retesting Respirator Users

Reference: 29 CFR 1910.134

An interesting question came my way this week. “If a worker has been fit-tested on one size respirator but now wants a different size facepiece, do they need to be fit-tested?” The easy answer is YES!  However, it wouldn’t be a very good Safety Tidbit if we didn’t dig a little deeper and look at the regulatory reason for the quick YES.

First, 1910.134(c)(1)(viii) requires training in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance. So, not quite the answer we’re looking for yet. More specifically, the employee must be fit tested with the same make, model, style, and size of respirator that will be used [1910.134(f)]. And to drill down a bit more, the employer shall ensure that an employee using a tight-fitting facepiece respirator is fit-tested prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) is used [1910.134(f)(2)].

Additionally, the employer shall conduct an additional fit-test whenever the employee reports (or, the employer, healthcare provider, supervisor, or program administrator makes visual observations of) changes in the employee's physical condition that could affect respirator fit. Conditions can include: facial scarring, dental changes, cosmetic surgery, or an obvious change in body weight [1910.134(f)(3)].

So why is this so important? For facepiece seal protection, of course. A tight-fitting air-purifying respirator doesn’t do much good if it doesn’t seal to the face. Ultimately, the employer shall not permit respirators with tight-fitting face pieces to be worn by employees who have:

·       facial hair that comes between the sealing surface of the face piece and the face or that interferes with valve function [1910.134(g)(1)(i)(A)]

·       any condition that interferes with the face-to-facepiece seal or valve function [1910.134(g)(1)(i)(B)]

·       corrective glasses or goggles or other personal protective equipment that may interfere with the face seal [1910.134(g)(1)(ii)]

Reminder: For all tight-fitting respirators, the employer shall ensure that employees perform a user seal check each time they put on the respirator [1910.134(g)(1)(iii)].

One last thing: Appropriate surveillance shall be maintained of work area conditions and degree of employee exposure or stress. When there is a change in work area conditions or degree of employee exposure or stress that may affect respirator effectiveness, the employer shall reevaluate the continued effectiveness of the respirator [1910.134(g)(2)(i)].

Hope this was helpful and thanks for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have an interesting safety or health question please let me know.