OSHA’s Respirator Standard – Interpreting the Changes

This final rule was introduced on January 8, 1998 and replaces the previous 29 CFR 1910.134 that was adopted by OSHA in 1971. The final rule went into effect on April 8, 1998. This new standard requires employers to establish and maintain a respiratory protection program with required worksite-specific procedures and elements for required respirator use to protect their employees that wear respirators. The major changes to this standard include:

• Definitions important to the standard
• Requirements for a program administrator. The employer is to designate a program administrator. The administrator needs to be qualified by appropriate training or experience which is comparable to the complexity of the program.
• The administrator is to oversee the respiratory protection program and conduct the required evaluations of program effectiveness.
• Classification of when respirator use is not required but permitted through “voluntary use”. Voluntary use applies for situations where respirator use is not required by OSHA or the employer, but is requested by employees. The employer may allow voluntary use if the respirator use does not create a hazard in itself. If voluntary respirator use is permissible, the employer must provide the basic advisory information on respirators, as presented in Appendix D of 1910.134. Although it is voluntary use, the employer must still ensure that the user is medically able to use the respirator and understand the requirements of cleaning, storing and maintaining the respirator so that it does not present a health hazard. One exception to the rule is that employers are not required to include in a written respiratory protection program those employees whose only use of respirators involves the voluntary use of filtering face pieces (dust masks).
• One strap dust masks vs. two strap dust masks. People usually wear the one-strap dust mask for comfort reasons, but they are not recommended. The two- strap dust mask is all together a different story. If a two-strap dust mask is to be worn to protect an employee from a specific hazard, then the employer must have a respiratory protection program. If the two-strap dust mask is only being used through voluntary use, then the employer is not required to develop a respiratory protection program.
• Establishment of a schedule for cartridge changing when gas/vapor respirators that do not have End-of-Service-Life Indicators (ESLI) are used. Respirator cartridges do not have an infinite use life. Chemical cartridges in particular become filled with contaminant and the vapors begin to penetrate into the worker’s breathing zone. OSHA recognized this in the new standard and now require all employers using cartridge respirators to either select those with a visible indicator or to have a change schedule. Your respirator manufacturer can assist you with the development of this schedule.
• Mandatory Medical evaluation questionnaire. Physical examinations are not automatic for respirator users. A mandatory medical evaluation is now required for all users. The results of the evaluation determine whether the employee gets a physical examination. This is based on a series of health and life-style risk factors. A normal, healthy, non-smoker may not need a physical. This medical evaluation must be conducted before the employee is fit tested or required to use a respirator in the workplace.
• Requirements for fit testing all tight-fitting respirators with a repeat frequency of at least every 12 months. Employees using tight-fitting facepieces must be fit tested prior to initial use, whenever a different respirator facepiece (size, style, model or make) is used and at least annually thereafter.
• Specific qualitative and quantitative fit testing protocols. Quantitative and qualitative fit testing must be performed in the negative pressure mode, regardless of the mode of operation (negative or positive pressure) that is used for respiratory protection. There are four OSHA accepted protocols for qualitative fit testing: isoamyl acetate, saccharin, bitrex and irritant smoke. There are three accepted protocols for quantitative fit testing: generated aerosol, portacount and controlled negative pressure.

Helpful Resources: http://www.osha.gov or Code of Federal Regulations 29 CFR 1910.134