SUNY Cobleskill Respiratory Protection Program & Policy
(OSHA 29 CFR 1910.134)
Prepared by Environmental Health and Safety Office, 2005
PURPOSE
The elements described in this program are designed to ensure the safe and effective usage of respiratory protection at the State University of New York at Cobleskilt (SUNY Cobleskill). This standard is a mandate under the NYS Department of Labor Public Employee Safety and Health (PESH) Bureau's respirator standard. The PESH standard is based on the Federal Occupational Safety and Health Administration (OSHA) respirator standard 29 CFR 191 0.134 (revised in 1998).
The guidelines in this program are designed to help reduce employee exposures against occupational dusts, fumes, mists, gases and vapors. The primary objective is to prevent excessive exposure to these contaminants. The PESH/OSHA respirator standard requires that employers establish and maintain an effective respiratory protection program and that employees are responsible for wearing the respirator and complying with the program. All elements of this respiratory protection written program are strictly based on adherence to the requirements of the governmental respirator standard.
INTRODUCTION
The PESH/OSHA respirator standard mandates that respirators be used only under certain circumstances. Where feasible, exposures to contaminants will be eliminated by engineering controls (example, general and local ventilation, enclosure or isolation, and substitution of a less hazardous process, product or chemical). However, respiratory protection may be needed in certain situations. For instance, respirators can be important for workers involved in certain maintenance operations. Or respirators may be necessary for those who work in areas where engineering controls have not yet been installed or are not feasible to install.
TYPES OF RESPIRATORS
A respirator is an enclosure that covers the nose and mouth or the entire face or head. There are two major classes of respirators:
(1) Air-purifying, to remove contaminants from the air. Air-purifying respirators are available in several varieties, including disposable respirators, half-mask and full-face respirators.
(2) Supplied-air respirators, which provide clean, breathable air from an uncontaminated source. There are several varieties of supplied-air respirators including loose-fitting respirators, (hoods, helmets or suits); air-line respirators or self-contained breathing apparatus (SCBA). As a general rule, this type of respirator is used only for the most hazardous exposures, i.e., in emergency cleanup of large-scale chemical spills or confined space retrieval and rescue operations or firefighter rescue.
PROGRAM ADMINISTRATION
The respirator standard requires the designation of a Program Administrator to oversee implementation of the standard. The Program Administrator for SUNY Cobleskill is Suna Stone-McMasters, Environmental Health and Safety Officer.
The Program Administrator duties include:
- Determining which tasks require respiratory protection.
- Selecting the proper respirator for the specific application.
- Conducting or coordinating employee training and fit testing.
- Ensuring that employees clean, maintain and properly store respirators.
- Conducting periodic evaluations of the respiratory program to ensure that it is effective.
Supervisors are responsible for:
- Ensuring that appropriate, approved type respirators are available for use (Please note The EH&S Office can assist supervisors and departments with advice about respirator types and selection but all costs for respirators, accessories, medical evaluations, etc. is the responsibility of each department.)
- Conducting periodic inspections to ensure that employees are maintaining their respirators, which would include cleaning, sanitizing, and proper storage.
Employees are responsible for:
- Attendance at all required trainings.
- Using the respirators in accordance with training requirements.
- Inspecting, cleaning, sanitizing, and proper storage of their respirator.
RESPIRATORY EQUIPMENT SELECTION
The Program Administrator is responsible for selecting the appropriate respiratory equipment based upon the following elements:
- The type(s) and concentrations of airborne contaminants.
- The characteristics and location of the hazardous area.
- The workers' activities in the hazardous area.
- The capabilities and limitations of the respirators.
- Duration of respirator use.
- Selection will be made according to section (d) of 29CFR 1910.134 OSHA Respiratory Protection Standard. (A copy of this standard is available by contacting Suna Stone-McMasters at the EH&S Office at ext. 5411 (Mackey Service Complex)).
- Only respirators having National Institute for Occupational Health (NIOSH) approval will be used.
Note: The Program Administrator may request assistance from outside sources such as regional occupational health clinical staff or the NYS Department of Health in determining appropriate respirator choices or the feasibility of engineering control alternatives.
Respirators currently approved for use at SUNY Cobleskill are:
- Moldex (disposable) 2200N95 Series
Particulate work tasks which may require use of this respirator include:
- Dusty Environments
- Sanding
- Grinding
- Buffing
- Polishing
- Paint Spraying
- Painting Tasks (general touch ups and repair)
- Pesticide Application
- North 7700 Series Half Mask
Work tasks which may require use of this type of respirator include all of the above work tasks (depending on exposure levels ) AND:
- Lab Packs
- Chemical Pouroffs and Consolidation
- Use of Paint Sprays/Epoxies/Enamels
- Boiler Room Cleanouts (i.e. breeching cleanouts in summer)
- Lab Chemical Cleanouts & Consolidations (i.e. pouring off solvents into consolidation drum. PLEASE NOTE: small-scale chemical pour-offs conducted in a properly functioning lab hood should not require respirator use)
- Jackhammering Refractory Lining in Boiler Breeching (due to potential for silica exposure this level of respirator will be the minimum level approved for use during this task).
- Wilson Full-Face 8600 Series
Work tasks which may require the use of this respirator include:
- Pour-offs or consolidation of waste animal parts OR mixed solvents where any amount of liquid formalin* is present.
- Pouring off solvent waste from accumulation containers into drums. Example: Consolidation of small amounts of mixed solvents waste (i.e. one gallon containers) into waste accumulation drums in the Wheeler Toxic Storage Building or the Fisheries and Wildlife Programs at Fisheries/Wildlife Storage and Home Economics Basement.
*Formalin is considered a severe eye irritant, as such a full-face respirator will be the minimum level of respirator required when consolidating formalin waste items. However, a respirator should not be necessary when handling formalin items in a properly functioning laboratory fume hood.
MEDICAL EVALUATIONS
Individuals assigned to tasks that require the use of respiratory protection will have a medical evaluation to determine if they are able to perform the work while wearing a respirator. All appointments for respirator medical evaluations will be coordinated through the Environmental Health and Safety Office. The medical evaluation will be given prior to an employee being allowed to wear a respirator. Periodic examinations will be conducted as necessary as determined by the physician or other licensed health care professional (PLHCP). All medical evaluation results must be in writing.
SUNY Cobleskill currently utilizes one or more of the following organizations to conduct employee respirator medical evaluations:
- Employee Health Service of the NYS Department of Civil Service (Albany)
- New York Center For Agricultural Medicine and Health (NYCAMH) affiliated with Bassett Hospital in Cooperstown)
- Eastern New York Occupational and Environmental Health Center (ENYOEHC) (Albany)
- Other licensed health care professional(s) (PLHCP) as needed
TRAINING
All employees who are required to use respiratory protection will be instructed on the proper selection, use, and limitations of this equipment. Supervisors of employees who may be required to wear a respirator will also need to attend at least one respirator training session even if they themselves do not wear a respirator. The training will be provided prior to any assignment requiring the use of a respirator. The training, conducted by Suna Stone-McMasters, Environmental Health and Safety Officer, will also include information on:
- Why the respirator is necessary and how improper fit, usage, or maintenance can adversely affect its protective value.
- Limitations and capabilities of the selected respirator.
- How to inspect, use, and check the seals of the respirator.
- Procedures for maintenance and storage of the respirator.
- How to use the respirator in emergency situations, including respirator malfunctions.
- How to recognize medical signs and symptoms that may limit respirator effectiveness.
- The general requirements of the PESH/OSHA respirator standards.
EMPLOYEE FIT TESTING
Employees required to wear a respirator must be fitted properly and tested for a face seal prior to use of the respirator in a contaminated area in accordance with Appendix A of the respirator standard 1910.134. Initial fit tests of employees shall be conducted by ENYOEHC or NYCAMH staff (either on our campus or at the respective health clinic sites in Albany or Cooperstown) utilizing quantitative (i.e. Porta-Count) fit test methods.
All fit-test activities will be coordinated through the Environmental Health and Safety Office. Records of fit test results shall be filed with the employee respirator training records. Fit checks shall be conducted at least annually. Field checks of fit-test can be conducted on the employee by the EH&S Officer utilizing a qualitative method, i.e. "Bitrex" or irritant smoke tubes.
RESPIRATOR INSPECTION AND MAINTENANCE
- The wearer of a respirator will inspect it daily whenever it is in use. (See "Inspection of Respirator")
- The Supervisor will periodically spot check respirators for fit, usage, and condition.
- Respirators not discarded after one shift use will be cleaned on a daily basis by the user, in accordance with the manufacturer's instructions.
- Respirators not discarded after one shift use will be stored in a suitable container away from areas of contamination.
- Whenever feasible, respirators not discarded after one shift use will be marked or stored in such a manner to assure that they are worn only by the assigned employee. If use by more than one employee is required, the respirator will be cleaned between uses.
INSPECTION OF RESPIRATOR
The respirator must be inspected daily while in use to be sure that it will function properly. Examine each part of the respirator for defects and discard if defective or replace with new parts.
Replacement parts must be from the same manufacturer and for the same model as the respirator in question. If other parts are substituted, the manufacturer's guarantee is not valid. Consult the Environmental Health and Safety Officer at ext. 5411 for more information.
Check the respirator for the following:
- Cracks, tears, decomposition, stiffening and distortion of the rubber face piece.
- Distorted or badly worn plastic adapter.
- Rubber gasket that contains cracks or scratches.
- Rubber inhalation valve flap that is stiffened, decomposed, or cut.
- Rubber head harness strapping that is stiffened, decomposed or cut.
- Snap fasteners on head straps or face piece that are worn or loose.
- Plastic exhalation valve seat that is distorted, decomposed or contains cuts.
- Rubber exhalation valve seat, valve flap, and/or valve cover that are distorted, decomposed, or contain cuts.
- Rubber filter clip that is distorted, decomposed, or contains cuts.
PROGRAM EVALUATION
The Program Administrator (EH&S Officer) shall conduct evaluations of the workplace as necessary to ensure that the provisions of the current written program are being effectively implemented and that it continues to be effective.
The Program Administrator shall regularly consult employees required to use respirators to assess the employees' views on program effectiveness and to identify any problems. Any problems that are identified during the assessment shall be corrected. Factors to be assessed include, but are not limited to:
- Respirator fit (including ability to use the respirator without interfering with effective workplace performance)
- Appropriate respirator selection for the hazards to which the employee is exposed
- Proper respirator use under the workplace conditions the employee encounters
- Proper respirator maintenance
| Department or Division:____________________________________________ | |
| Process/Operation:____________________________________________ | |
| Reason for requesting respirator evaluation:____________________________________________ | |
| Requested by:____________________________________________ | |
| I. Employee Exposure Evaluation: | |
|---|---|
| Contaminant(s) or other respiratory hazard(s):___________________________________________________ | |
| Estimated Concentration(s) (Reference sampling data if known):___________________________________________________ | |
| Attatch Copy/Copies of Material Safety Data Sheets | |
| MSDS attatched: yes_______ no_______ | |
| Chemical state of contaminant(s):___________________________________________________ | |
| Physical form of contaminant(s):___________________________________________________ | |
| PEL/TWA (if known):___________________________________________________ | |
| II. Respirator Determination | |
| ______Exposure is documented to below the exposure limits and use by employee is voluntary. | Respirator use is "not required" under the standard. Respirator may be used if desired. Go to section III a. |
| ______Exposure is documented to below the exposure limits and use by employees is required by a job rule or procedure. | Respirator use is required under the standard. Go to section III b. |
| ______Exposure may exceed exposure limit and maximum concentration is known. | Respirator use is required under the standard. Go to section III b. |
| ______Exposure is not characterized ("cannot identify or reasonably estimate employee exposure"). | Exposure is considered IDLH*(Immediately Dangerous to Life or Health). STOP!!! Task cannot be safely performed!!! |
| *The minimum level of respiratory protection needed in an IDLH atmosphere is a SELF-CONTAINED BREATHING APPARATUS (SCBA). There are currently no approved uses of an SCBA at SUNY Cobleskill except by outside emergency responders. | |
| Section III a. Voluntary use of a respirator**. | |
| Indicate make, model, and approval number of respirator selected and indicate any limitations on its use. If respirator is a chemical cartridge or filter type respirator, indicate the frequency required for cartridge or filter replacement. | |
| Type of respirator:_________________________________________ | |
| Manufacturer:_________________________________________ | |
| Model No.:_________________________________________ | |
| Approval No.:_________________________________________ | |
| Limitations:_________________________________________ | |
| Cartridge/filter change schedule (if applicable):_________________________________________ | |
| Prepared by (print):_________________________________________ | |
| Signature:_________________________________________ | |
| Date:_________________________________________ | |
| **Note Re: Voluntary use of respirators: The basic advisory information on respirators, as presented in Appendix D of the PESH/OSHA respirator standard 29CFR 1910.134, shall be provided in any written or oral format to those employees who wear respirators when such use is not required by this section or by the employer. (Copies available through Suna Stone-McMasters at the Environmental Health and Safety Office, ext. 5411. | |
| Section III b. Respirator use is required by the standard. | |
| Indicate make, model, and approval number of respirator selected and indicate any limitations on its use. If respirator is a chemical cartridge or filter type respirator, indicate the frequency required for cartridge or filter replacement. | |
| Type of respirator:_________________________________________ | |
| Manufacturer:_________________________________________ | |
| Model No.:_________________________________________ | |
| Approval No.:_________________________________________ | |
| Limitations:_________________________________________ | |
| Cartridge/filter change schedule (if applicable):_________________________________________ | |
| Basis for determining cartridge/filter change schedule: (Include references to published literature and/or industrial hygiene data, where appropriate)_________________________________________ | |
| Prepared by (print):_________________________________________ | |
| Signature:_________________________________________ | |
| Date:_________________________________________ | |
OSHA LINKS
Respiratory Protection. 1910.134Respiratory Protection. 1910.134 App. A
Respiratory Protection. 1910.134 App. B-1
Respiratory Protection. 1910.134 App. B-2
Respiratory Protection. 1910.134 App. C
Respiratory Protection. 1910.134 App. D
To obtain a copy of the Respirtory Protection Policy, email your request to Suna Stone-McMasters.