Respiratory Protection

In various work sites throughout the United States (U.S.), millions of workers are required to wear respirators to protect against insufficient oxygen environments, harmful dusts, fogs, smokes, mists, gases, vapors, and sprays. These hazards may cause cancer, lung impairment, diseases, or even death. The Occupational Health and Safety Administration (OSHA) reports that compliance with the OSHA Respiratory Protection Standard could avert hundreds of deaths and thousands of illnesses annually https://www.osha.gov/respiratory-protection.

Respirators protect the user through the removal of contaminants from the air. Respirators of this type include particulate respirators, which filter out airborne particles, and air-purifying respirators or “gas masks” which filter out chemicals and gases. Other respirators protect the user by supplying clean respirable air from another source. Respirators in this category include airline respirators, which use compressed air from a remote source, and self-contained breathing apparatus (SCBA), which include their own air supply.

OSHA requires employers to ensure the safety of all employees in the work environment, including by providing respiratory protection whenever necessary to protect against chemical, environmental, or physical irritants and hazards. Respirators should only be used when engineering control systems are not feasible or during the interim period when engineering controls are being installed. Engineering control systems, such as adequate ventilation or scrubbing of contaminants, are the preferred control methods for reducing worker exposures.

In fiscal year 2020, of the top ten most frequently cited standards following inspections of work sites by OSHA, the third-ranked most cited violation by OSHA was associated with respiratory protection https://www.osha.gov/top10citedstandards. Measures to provide respiratory protection to workers on the job site should be included in the preparation of a Health and Safety Plan (HASP), a Job Hazard Analysis (JHA), an Activity Hazard Analysis (AHA), or a Job Safety Analysis (JSA).

OSHA Standards

OSHA’s respirator standard requires the use of respirators to protect employees from breathing contaminated and/or oxygen-deficient air when effective engineering controls are not feasible, or while engineering controls are being instituted. Several other OSHA regulations also require the use of respirators. OSHA addresses respiratory protection in specific standards for the general industry, construction, and maritime scenarios. The standards under the general industry scenario are addressed under 29 Code of Federal Regulations (CFR) 1910.134 https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.134, whereas the standards under the construction scenario addressed under 29 CFR 1926.103 are identical to standards under the general industry scenario. Standards under the maritime scenario are addressed under 29 CFR 1915.154, 29 CFR 1917.92, and 29 CFR 1918.102, and are not discussed in this article.

There are 28 OSHA-approved State Plans, operating state-wide occupational safety and health programs. State Plans are required to have standards and enforcement programs that are at least as effective as OSHA's and may have different or more stringent requirements. Information on which states have OSHA-approved plans are at this link https://www.osha.gov/stateplans, and should be reviewed for the applicable State that one may be working in.  

Some of the general requirements under the identical OSHA standards for the general industry and construction scenarios are as follows.

1. The employer is required to develop and implement a written respiratory protection program with required worksite-specific procedures and elements for required respirator use. The program must be administered by a suitably trained program administrator. Also, certain program elements may be required for voluntary use to prevent potential hazards associated with the use of the respirator.
2. In any workplace where respirators are necessary to protect the health of the employee or whenever respirators are required by the employer, the employer shall establish and implement a written respiratory protection program with worksite-specific procedures. The program shall be updated as necessary to reflect those changes in workplace conditions that affect respirator use. The employer shall include in the program the following provisions of this section:
   • Procedures for selecting respirators for use in the workplace.
   • Medical evaluations of employees required to use respirators.
   • Fit testing procedures for tight-fitting respirators.
   • Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations.
   • Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators.
   • Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators.
   • Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations.
   • Training of employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance.
   • Procedures for regularly evaluating the effectiveness of the program.
3. The employer shall designate a program administrator who is qualified by appropriate training or experience that is commensurate with the complexity of the program to administer or oversee the respiratory protection program and conduct the required evaluations of program effectiveness.
4. The employer shall provide respirators, training, and medical evaluations at no cost to the employee.
5. The employer shall select and provide an appropriate respirator based on the respiratory hazard(s) to which the worker is exposed and workplace and user factors that affect respirator performance and reliability.
6. The employer shall select a National Institute of Occupational Safety and Health (NIOSH)-certified respirator. The respirator shall be used in compliance with the conditions of its certification.
7. The employer shall identify and evaluate the respiratory hazard(s) in the workplace; this evaluation shall include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant's chemical state and physical form. Where the employer cannot identify or reasonably estimate the employee exposure, the employer shall consider the atmosphere to be Immediately Dangerous to Life or Health (IDLH).
8. The employer shall select respirators from a sufficient number of respirator models and sizes so that the respirator is acceptable to, and correctly fits, the user.

Types of Respiratory Protection

As previously indicated, there are basically the following two categories of personal protective equipment (PPE) that provide respiratory protection to workers:

• Air-purifying respirators that remove contaminants from the air
  • Particulate respirators
  • Vapor and gas respirators (or “gas masks”)
  • A combination of particulate and vapor/gas respirators
• Respirators that provide clean, respirable air from another source
  • Airline respirators, which use compressed air from a remote source
  • SCBAs, which include their own air supply

OSHA requires that respirators be selected based on hazards to which the worker is or anticipated to be exposed (i.e., vapors, particulates, deficient oxygen, or a combination of one or more), and that the respirators are certified by NIOSH. Most if not all respirators remove contaminants from the air by using cartridges. These cartridges use sorbent material to filter the gas or vapor molecules. Typically, the sorbent is activated carbon. Different chemical treatments may also be added to the surface of the activated carbon to adsorb different types of gases or vapors. NIOSH uses a classification system to identify the different types of contaminants that these treated carbon grains will capture. The type(s) of cartridges to use will be dependent on the contaminants present in the workplace.

To verify that respirators and filters/cartridges are certified by NIOSH, under the 40 CFR Part 84 approval system, cartridges and filters are marked with “NIOSH”, the manufacturer’s name and part number, and an abbreviation to indicate the cartridge (e.g., organic vapor [OV], acid gas [AG]) or filter (e.g., N95, P100) type. All cartridges and filters are to be supplied with a matrix approval label, usually as an insert in the box. This label shows the NIOSH-approved configurations and includes the “TC number”, component parts, and cautions and use limitations.

The various types and brands of respirators are not summarized in this article, and the reader is referred to the OSHA website https://www.osha.gov/etools/respiratory-protection and the various vendor websites available on the Internet for that information.

Respiratory Protection General Procedures

The proper respirator size for an employee is determined through an appropriate “fit test”, which employees using negative or positive pressure tight-fitting facepiece respirators must pass following the procedures detailed in OSHA’s respirator standard. Once an employee has passed a fit test for a specific tight-fitting facepiece respirator, the employee is to use that specific facepiece respirator on the job site. The employee must be fit tested with the same make, model, style, and size of respirator that will be used in the workplace.

Fit testing of all negative or positive pressure tight-fitting facepiece respirators is required prior to initial use, whenever a different respirator facepiece is used, and at least annually thereafter. An additional fit test is required whenever there are 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).

Each time an employee uses their fit-tested facepiece respirator, a seal check is required to be conducted by the employee to see if the employee has correctly put on the respirator and adjusted it to fit properly. Please note that a seal check is different from a fit test, which is a method used to select the right size respirator for the employee.

Before an employee is first fit tested or required to use a respirator in the workplace for the first time, the employer must provide a medical evaluation to determine the employee’s ability to use a respirator. A physician or other licensed health care professional must perform the medical evaluation using the medical questionnaire contained in Appendix C of 29 CFR 1910.134 or an initial medical examination that obtains the same information. After the initial medical evaluation, subsequent evaluations must be provided to the employee annually.

The employer must provide for the cleaning and disinfecting, storage, inspection, and repair of respirators used by employees according to the procedures in 29 CFR 1910.134. Also, the employer must provide training to employees who are required to use respirators. The training must be comprehensive, understandable, and recur annually, and more often if necessary. At a minimum, training should include:

• Why the respirator is necessary and how improper fit, use, or maintenance can compromise its protective effect.
• Limitations and capabilities of the respirator.
• Effective use in emergency situations.
• How to inspect, put on and remove, use, and check the seals.
• Maintenance and storage.
• Recognition of medical signs and symptoms that may limit or prevent effective use.
• General requirements of OSHA’s respirator standard, 29 CFR 1910.134.

During preparation of a Health and Safety Plan (HASP), a Job Hazard Analysis (JHA), an Activity Hazard Analysis (AHA), or a Job Safety Analysis (JSA), OSHA has a web-based tool that can be used to assist in the selection of the appropriate respiratory protection, developing respirator change schedules for workers on a job site, and helping one to comply with the OSHA respirator standard. This tool is called the “Respiratory Protection eTool” which is accessed at https://www.osha.gov/etools/respiratory-protection. On this web page, there are dropdown menus where one can get assistance in selecting the appropriate respirator for the task at hand, and to develop appropriate change schedules for particulate respirators and air-purifying respirators that use cartridges to filter out gases and chemicals.

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