U of M Respiratory Protection Program

PROCEDURE 2.6.1.
Responsible Officer
Fay Thompson

Responsible Department
Environmental Health and Safety

• Occupational Health and Safety Act, Dept. of Labor and Industry, OSHA MS Ch. 182, MR 5205, MR 5206, MR 5207
  
• Hazardous Waste Operations and Emergency Response (HAZWOPER) 29 CFR 1910.120
  
• Respiratory Protection 29 CFR 1910.134
  
• Asbestos 29 CFR 1910.1001, 29 CFR 1926.1101
  
• National Institute for Occupational Health and Safety (NIOSH) 42 CFR 84
  
• Environmental Protection Agency Worker Protection Standard 40 CFR 170
  
• Centers for Disease Control (CDC) Vol 33 RR-13, 11/28/94, Guidelines for Preventing the Transmission of Mycobacterium Tuberculosis in Health-Care Facilities, 1994
  
• CDC Vol 44 RR-8, 5/28/93, Recommended Infection Control Practices for Dentistry, 1993
  et alibi

Every worker who uses a negative pressure cartridge or canister respirator must be included in the program. Workers using other types of respirators may be required to comply with some program requirements.

For example, include employees who use a powered air purifying respirator (PAPR) or an atmosphere supplying respirator in the medical monitoring, training, maintenance and quality assurance components of this program. Under some conditions of very great exposure to hazardous atmospheres, quantitative fit testing may be required.

Employees who work in areas where "emergency use only" SCBA pressure-demand respirators are available shall be trained in SCBA use, but medical monitoring is not required.

Lightweight single use respirators may sometimes be worn in situations where respiratory protection is required, such as to control exposure to airborne pathogens. However, workers must be fit tested with the make and model of respirator they will wear, instructed in its use, and meet the other maintenance and quality assurance components requirements of this program.

Users of lightweight single-use respirators are not required to be included in this program if they work in situations where overexposure to chemical substances is not going to occur and respirator misuse is not likely. These exposures are generally described as nuisance situations where the worker is more comfortable with some respiratory protection. Workers may also use lightweight single-use respirators to control exposure to a non-occupational condition such as an allergy without being included in the program.

It is the employing department's responsibility to provide respirators to control occupational exposures and to assure that the requirements of this program are met.

An employee has the responsibility to use provided respiratory protection in accordance with this program. Male employees must remain clean shaven where an issued respirator touches their face; this is to assure proper fit of the respirator under conditions of use.

Respirator selection will be made in cooperation between Department of Environmental Health and Safety (DEHS) Occupational Health and Safety staff and the examining medical provider. Any choice of respirator will be based on American National Standard Practices for Respiratory Protection Z88.2. Required air quality monitoring of the workplace will be done by DEHS which will maintain records. Monitoring results will also be provided to the employing department and affected individuals.

1. Health of the worker and ability to wear a respirator
2. Nature of the hazard, e.g. toxicity, chemical and physical properties
3. Extent of the hazard (concentration) and time of exposure
4. Work requirements and conditions
5. Characteristics and limitations of available respirators

DEHS will dispense respirators and cartridges from its stock when fit testing is performed at its location. The Employing Department must provide maintenance and replacement parts, sanitary storage facilities, and will maintain certain records.

Generally, DEHS assures that the requirements of this program are met.

1. Employee Fitness
   1. Medical monitoring - The Employing Department must make employees available and pay for medical monitoring. Departments may contract with a local health care provider. Within the University of Minnesota, two clinics are available to perform monitoring; to schedule appointments contact the Duluth Student Health Clinic at (218) 726-8155 or Twin City Campus Boynton Health Service at (612) 626-0118. See Appendix A: Pulmonary Testing/Respirator Fitting memo)

      Persons must not be assigned to tasks requiring the use of respirators unless it has been determined that they are physically able to perform the work and use the equipment. The Examining Physician responsible for the employee's care will determine what diagnostic method is necessary to determine whether medical conditions exist which would prohibit or limit respirator use. Pulmonary function tests, including forced vital capacity (FVC) and forced expiratory volume at one second (FEV1.0), and a medical questionnaire may be given to employees. (See Appendix sections B1: Respiratory Program Medical Evaluation Form, B2: Medical Evaluation Form for Asbestos Workers (Initial Medical Questionnaire) and B3: Annual Medical Questionnaire for Asbestos Workers)

      Note: The Respiratory Medical Evaluation Form may be used by the Examining Physician to evaluate any person, except asbestos workers, who may use a respirator. Asbestos workers must be asked to fill out Appendix B2: Respirator Program Medical Evaluation Form for Asbestos Workers. Asbestos workers are individuals who routinely work in areas where exposure might exceed the OSHA action level for asbestos. Presently, the action level means an airborne concentration of asbestos, tremolite, anthophyllite, actinolite, or a combination of these minerals of 0.1 fibers/cc of air as calculated on an 8-hour time weighted average. Considering the results of current workplace monitoring, the only "asbestos workers" at the University are those who remove pipe covering or other materials containing unbound asbestos. However, if an employee requests a respirator because of a belief that exposure to asbestos will exceed the action level for asbestos, then the employee must meet all requirements of the program for asbestos workers including completion of Appendix B2 and B3.

   2. Medical certification - Pertinent health factors, conditions on the job site, and the employee's health status will be considered by the Examining Physician. Occupational Health and Safety staff will provide information about the working environment and characteristics of respirators. The Examining Physician will certify whether the employee is capable of wearing a respirator and describe any physical limitation. See Appendix B2: Respiratory Program Medical Evaluation Form for Asbestos Workers and B3: Annual Medical Questionnaire for Asbestos Workers and Appendix C: Medical Certification.

   3. Medical re-certification - The Employing Department must make employees available on the schedule prescribed by the Examining Physician.

   4. Fit testing - Fit testing must be done whenever something happens which could affect the fit of a respirator such as when an employee's facial characteristics change or the respirator design changes. Fit testing is required annually for workers exposed to benzene and formaldehyde and semi-annually for workers exposed to asbestos, arsenic, lead, acrylonitrile. Fit testing must be performed by DEHS staff or designated individuals. Fit testing will be performed for an individual after the employee presents the Medical Certificate. Workmen with facial hair in the respirator area will not be issued respirators requiring a fit test because Occupational Health and Safety staff cannot ensure that the respirator will fit under conditions of use. See Appendix D1: Qualitative and Quantitative Fit Testing Procedures For Elastomeric (rubber or plastic) Repirators or Appendix D2: Qualitative Respirator Fit Testing Procedures For Single Use Lightweight Respirators.
      1. The Employing Department must make employees available for this testing. The Employing Department will be responsible to make appointments with DEHS for the fit testing.
         1. Fit testing will be done after the employee's annual medical evaluation, if one is required. The employee must bring the original copy of the Medical Certification to DEHS Occupational Health and Safety staff before a fit test will be done.

         2. Semi-annual fit testing for asbestos workers may be done by direct appointment with DEHS Occupational Health and Safety staff. A photocopy of the Medical Certification must be brought by the employee to this fit test. The original copy will remain in the employee's personnel file.

      2. DEHS will notify the Employing Department that fit testing has been done and provide information about the respirator issued. See Appendix C: Medical Certification and Record of Fit Test and Respirator Issued.

2. Monitoring of Air Contaminants
   1. Air contaminant levels during routine operations will be monitored by DEHS Occupational Health and Safety staff before the type of respiratory protection is selected. Existing operations undergoing a change that might significantly alter the concentration of air contaminants should be re-evaluated by DEHS to determine if another method of protection is appropriate. Results of monitoring will be sent to the Employing Department. Contact DEHS at (612) 626-6002 in Minneapolis, or in Duluth at (218) 726-7139.

   2. In emergency situations, activate your local emergency response system by dialing 911. On the Minneapolis or Saint Paul Campuses after hours response by the Department of Environmental Health and Safety is always available by dialing the University of Minnesota Police dispatcher at 911. From coordinate locations dial the University of Minnesota Police dispatcher at 612-624-7828 if you need after hours response by the Department of Environmental Health and Safety. Where on-site measurements are not practicable, the hazard potential will be evaluated by DEHS on-site or assistance may be given by telephone.

   3. Categories of respiratory hazard
      1. Oxygen deficient atmospheres* require the use of an independent respirable atmosphere. See Appendix E-: Categories of Respiratory Hazard, for acceptable breathing devices.

      2. Immediately dangerous conditions* are defined as: Conditions that pose an immediate threat to life or health and/or conditions that pose an immediate threat of severe exposure to contaminants that are likely to have delayed adverse affects on health. Acceptable devices are listed in Appendix E: Categories of Respirator Hazard.

      3. Conditions of known contaminant concentrations not immediately dangerous to life. Acceptable respirators include those listed in Appendix E: Categories of Respirator Hazard.

      Note: The Confined Space Entry Program must be followed. An attendant must be present in a safe location at the entrance to oxygen deficient or immediately dangerous areas in order to maintain communication and to provide proper rescue equipment in case of emergency.

3. Selection of Respirators
   1. Respirators will be selected by DEHS based on the Examining Physician's certification and the exposure hazard. See Appendix F1: Respirator Classification, Selection and Certification, F2: Capabilities and Limitations of Respirators, F3: Respirator Protection Factors, F4: Identification of Respirators, Canisters, and F4 Table 1 Cartridges/Identification Color Code for Respirator Canisters/Cartridges.

4. Distribution
   1. Respirator Distribution - Whenever possible, reusable respirators should be assigned to individual workers for their exclusive use. Permanently assigned respirators must be durably marked with the name of that person and the date issued. When disposable respirators are issued, the same models that were fit tested must be kept in stock.

   2. DEHS will issue a respirator from its stock when an employee is first fit tested or when a new type of respirator is issued on a subsequent fit. The Employing Department must provide CUFS account number to pay for the issued respirator and cartridges, or provide a replacement to DEHS stock or, the employee may bring their own assigned respirator in for fit testing.

   3. The Employing Department must maintain a stock of replacement respirators and/or cartridges and issue them to the employee as necessary.

   4. Those who issue canisters-cartridges must see that they are properly labeled and colored before they are put into service. The labels and colors must be maintained until they are disposed.

   5. If it is necessary to replace a reusable respirator because of loss or damage, the newly issued respirator must be fit tested before it is used. This is to ensure that the respirator is not defective.

5. Training
   1. Employees who will use respirators will be given training on a yearly basis by DEHS. See Appendix G: Training Requirements. Training may be performed after fit testing is done or other arrangements may be made. The Employing Department will maintain records of training.

   2. In areas where job tasks and materials change, DEHS must be contacted to provide an updated training.

6. Inspection, Care, Maintenance and Storage of Reusable Respirators (single use respirators are exempt)
   1. Inspection
      1. Each respirator must be inspected routinely before and after each use by the employee using it. See Appendix H(1,2,3,4) which describes inspection, care, maintenance and storage of respirators.

      2. Respirators for emergency use must be inspected after each use, or at least once each month, by the employees to whom they are assigned. Inspections of emergency respirators should be done according to manufacturers' instructions. See appendix H2: Emergency Respirator Inspection.

   2. Cleaning and Disinfecting (See Appendix H3: Cleaning and Disinfection of Respirators)
      1. Respirators issued for exclusive use must be cleaned and disinfected after eight hours of use, or as necessary to ensure protection for the wearer.

      2. Respirators used by more than one person and emergency respirators must be cleaned and disinfected after each use as arranged by the Employing Department.

   3. Maintenance
      1. The Employing Department must arrange for replacement or repairs by experienced persons with parts designed for the respirator. Do not attempt to replace components or make adjustments or make repairs beyond the manufacturer's recommendations.

      2. Self-contained breathing apparatus or air line respirators must be returned to a professional repair service or the manufacturer when it is required for repair or testing.

   4. Storage
      1. After inspection, cleaning and necessary repair, store respirators to protect them against dust, sunlight, heat, extreme cold, excessive moisture, or damaging chemicals. The Employing Department must assure that adequate facilities are available. (See Appendix H4: Storage of Respirators)

7. Program Evaluation
   1. DEHS will evaluate this program through random inspections to assure that respirators are properly used, cleaned and maintained.

   2. Periodically DEHS will survey to determine whether anyone is using a respirator who is not included within the program. (See Appendix I: Respirator Use Questionnaire)

   3. Program evaluation reports will be sent to the Employing Department.

8. Record keeping
   1. The Employing Department will maintain the following records:
      1. Operations requiring respiratory protection, specific respiratory protection used, and names of employees who wear the respirators. Number and types of respirators in use (See Appendix J: Department Record of Tasks/Employees Requiring Respiratory Protection). These records must be maintained for 30 years.

      2. A record of employee training programs. Records will be maintained for one year past the date of employment of that employee.

      3. Fit tests performed on University employees. The records will be maintained for 30 years.

      4. Records on respirator inspection and maintenance activities. These records must be maintained for five years.

   2. The Examining Physician will maintain medical records according to Minnesota law. Records may be maintained at Boynton Health Service or at the Duluth Health Service.

   3. DEHS will maintain asbestos exposure measurements for thirty years. Monitoring records will include the following information.
      1. Date of measure
      2. Operation involving exposure
      3. Sample and analytic measure
      4. Number, duration and results
      5. Type of respiratory protection worn
      6. Name, social security number and exposure of employees whose exposures are represented.