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Sample Respiratory Protection
Program
This Sample Respiratory Protection Program is for a
hypothetical company that has chosen to interpret certain
provisions of 29 CFR 1910.134 in ways that could be different
from the way another company might choose to implement it.
The following checklist is provided to assist the employer
in determining if their respiratory protection program contains all the required
elements. The checklist itself is not included in the written program.
A written respiratory program that is specific to your
workplace and covers the following:
-
Procedures for selecting respirators.
-
Medical evaluations for employees required to wear
respirators.
-
Fit testing procedures.
-
Routine use procedures and emergency respirator use
procedures.
-
Procedures for ensuring adequate air quality for supplied air
respirators.
-
Training in respiratory hazards.
-
Training in proper use and maintenance of respirators.
-
Program evaluation procedures.
-
Procedures for ensuring that workers who voluntarily wear
respirators (excluding filtering face-pieces) comply with the medical
evaluation, and cleaning, storing and maintenance requirements of the standard.
Designate a program administrator who is qualified to
administer the program.
Update the written program as necessary to account for
changes in the workplace affecting respirator use.
Provide equipment, training, and medical evaluation at no
cost to employees.
SAMPLE RESPIRATORY
PROTECTION PROGRAM
Small Entity Compliance Guide
TABLE OF CONTENTS
Small Entity Compliance Guide:
Sample Respiratory Protection Program
1.0 Purpose
2.0 Scope and Application
3.0 Responsibilities
4.0 Program Elements
5.0 Program
Evaluation
6.0
Documentation and Recordkeeping
Small Entity Compliance Guide
This Sample Respiratory Protection Program is for
demonstration purposes only. XYZ Seating is not intended to represent an actual
company. XYZ is a hypothetical company that has chosen to interpret certain
provisions of 29 CFR 19Published by the Connecticut Department of Labor, Project
Management Office.134 in ways that could be different from the way another
company might choose to implement it.
Small Entity Compliance Guide
1.0 Purpose
XYZ Seating has determined that employees in the Prep,
Coating, Assembly, and Maintenance departments are exposed to respiratory
hazards during routine operations. These hazards include wood dust, particulate,
and vapors, and in some cases represent Immediately Dangerous to Life or Health
(IDLH) conditions. The purpose of this program is to ensure that all XYZ Seating
employees are protected from exposure to these respiratory hazards.
Engineering controls, such as ventilation and substitution
of less toxic materials, are the first line of defense at XYZ Seating; however,
engineering controls have not always been feasible for some of our operations,
or have not always completely controlled the identified hazards. In these
situations, respirators and other protective equipment must be used. Respirators
are also needed to protect employees' health during emergencies. The work
processes requiring respirator use at XYZ Seating are outlined in Table 1 in the
Scope and Application section of this program.
In addition, some employees have expressed a desire to
wear respirators during certain operations that do not require respiratory
protection. As a general policy XYZ Seating will review each of these requests
on a case-by-case basis. If the use of respiratory protection in a specific case
will not jeopardize the health or safety of the worker(s), XYZ Seating will
provide respirators for voluntary use. As outlined in the Scope and Application
section of this program, voluntary respirator use is subject to certain
requirements of this program.
2.0 Scope and Application
This program applies to all employees who are required to
wear respirators during normal work operations, and during some non-routine or
emergency operations such as a spill of a hazardous substance. This includes
employees in the Prep, Coating (Spray Booth), Assembly, and Maintenance
departments. All employees working in these areas and engaged in certain
processes or tasks (as outlined in the table below) must be enrolled in the
company's respiratory protection program.
In addition, any employee who voluntarily wears a
respirator when a respirator is not required (i.e., in certain maintenance and
coating operations) is subject to the medical evaluation, cleaning, maintenance,
and storage elements of this program, and must be provided with certain
information specified in this section of the program.1
1Employees who usually voluntarily wear filtering facepieces
(dust masks) are not subject to the medical evaluation,
cleaning, storage, and maintenance provisions of this program.
Employees participating in the respiratory program do so
at no cost to them. The expense associated with training, medical evaluations
and respiratory protection equipment will be borne by the company.
| TABLE 1: VOLUNTARY AND
REQUIRED RESPIRATOR USE AT XYZ SEATING |
| Respirator |
Department/Process |
| Filtering facepiece (dust mask) |
Voluntary use for warehouse workers |
| Half-facepiece APR or PAPR with PPublished by the
Connecticut Department of Labor, Project Management Office0 filter |
Prep and Assembly
Voluntary use for maintenance workers when cleaning spray
booth walls or changing spray booth filter |
| SAR, pressure demand, with auxiliary SCBA |
Maintenance - dip coat tank cleaning |
| Continuous flow SAR with hood |
Spray booth operations
Prep (cleaning)* |
| Half-facepiece APR with organic vapor cartridge |
Voluntary use for Dip Coat Tenders, Spray Booth Operators
(gun cleaning), and Maintenance Workers (loading coating agents into supply
systems) |
| Escape SCBA |
Dip Coat, Coatings Storage Area, Spray Booth Cleaning
Area |
*until ventilation is installed.
3.0 Responsibilities
Program
Administrator
The Program Administrator is responsible for administering
the respiratory protection program. Duties of the program administrator include:
-
Identifying work areas, processes or tasks that require
workers to wear respirators, and evaluating hazards.
-
Selection of respiratory protection options.
-
Monitoring respirator use to ensure that respirators are used
in accordance with their certifications.
-
Arranging for and/or conducting training.
-
Ensuring proper storage and maintenance of respiratory
protection equipment.
-
Conducting qualitative fit testing with Bitrex.
-
Administering the medical surveillance program.
-
Maintaining records required by the program
-
Evaluating the program.
-
Updating written program, as needed.
The Program Administrator for Company XYZ Seating is
___________________________ .
Supervisors
Supervisors are responsible for ensuring that the
respiratory protection program is implemented in their particular areas. In
addition to being knowledgeable about the program requirements for their own
protection, supervisors must also ensure that the program is understood and
followed by the employees under their charge. Duties of the supervisor include:
-
Ensuring that employees under their supervision (including
new hires) have received appropriate training, fit testing, and annual medical
evaluation.
-
Ensuring the availability of appropriate respirators and
accessories.
-
Being aware of tasks requiring the use of respiratory
protection.
-
Enforcing the proper use of respiratory protection when
necessary.
-
Ensuring that respirators are properly cleaned, maintained,
and stored according to the respiratory protection plan.
-
Ensuring that respirators fit well and do not cause
discomfort.
-
Continually monitoring work areas and operations to identify
respiratory hazards.
-
Coordinating with the Program Administrator on how to address
respiratory hazards or other concerns regarding the program.
Employees
Each employee has the responsibility to wear his or her
respirator when and where required and in the manner in which they were trained.
Employees must also:
-
Care for and maintain their respirators as instructed, and
store them in a clean sanitary location.
-
Inform their supervisor if the respirator no longer fits
well, and request a new one that fits properly.
-
Inform their supervisor or the Program Administrator of any
respiratory hazards that they feel are not adequately addressed in the workplace
and of any other concerns that they have regarding the program.
4.0 Program Elements
Selection Procedures
The Program Administrator will select respirators to be
used on site, based on the hazards to which workers are exposed and in
accordance with all OSHA standards. The Program Administrator will conduct a
hazard evaluation for each operation, process, or work area where airborne
contaminants may be present in routing operations or during an emergency. The
hazard evaluation will include:
1) Identification and development of a list of hazardous
substances used in the workplace, by department, or work process.
2) Review of work processes to determine where potential
exposures to these hazardous substances may occur. This review shall be
conducted by surveying the workplace, reviewing process records, and talking
with employees and supervisors.
3) Exposure monitoring to quantify potential hazardous
exposures. Monitoring will be contracted out. XYZ Seating currently has a
contract with ABC Industrial Hygiene Services to provide monitoring when needed.
The results of the current hazard evaluation are the
following:
(Table 3 at the end of this program contains the sampling
data that this section was based on).
Prep-sanding: Ventilation controls on some sanders
are in place, but employees continue to be exposed to respirable wood dust at
2.5 - 7.0 mg/m3 (8 hour time-weighted-average, or TWA).
Half-facepiece APRs with PPublished by the Connecticut Department of Labor,
Project Management Office0 filters and goggles are required for employees
sanding wood pieces. PAPRs will be available for employees who are unable to
wear an APR.
Prep-cleaning: Average methylene chloride exposures
measured at 70 ppm based on 8 hr. TWA exposure results for workers
cleaning/stripping furniture pieces. Ventilation controls are planned, but will
not be implemented until designs are completed and a contract has been set for
installation of the controls. In the meantime, employees must wear supplied air
hoods with continuous air flow, as required by the Methylene Chloride Standard
19Published by the Connecticut Department of Labor, Project Management
Office.Published by the Connecticut Department of Labor, Project Management
Office52.
Coating-spray booth: XYZ Seating has decided to
take a conservative approach and require all employees to wear supplied air
respirators when working inside the spray booth. Based on exposure data in
published reports on the same type of spray booth operations, the Program
Administrator has determined that an SAR in the continuous flow mode will
provide sufficient protection. Spray booth employees may opt to wear
half-facepiece APRs with organic vapor cartridge when cleaning spray guns.
Coating-dip coat, and drying: Exposures are kept
within PELs by ventilation, and employees generally enter the dip coat area for
short time periods (up to one hour). Vapors could leak into the dip coat and
drying areas if the ventilation system is not running at peak efficiency. Odors
in this area are often unpleasant even at the levels maintained by the
ventilation system. While XYZ Seating notes that respiratory protection is not
required in this area, the company recognizes employee concern about breathing
vapors and about having to work in an unpleasant environment. Accordingly,
employees may voluntarily choose to wear a half-facepiece APR with organic vapor
cartridges when working in this area.
Assembly: Ventilation controls on sanders are in
place, but employees continue to be exposed to respirable wood dust at 2.5 - 6.0
mg/m3
(8 hour TWA); half-facepiece APRs with PPublished by the Connecticut
Department of Labor, Project Management Office0 filters and goggles are required
for employees sanding wood pieces in the assembly department. PAPRs will be
available for employees who are unable to wear an APR. The substitution for
aqueous-based glues will eliminate exposures to formaldehyde, methylene
chloride, and epoxy resins.
Maintenance: Because of potential IDLH conditions,
employees cleaning dip coat tanks must wear a pressure demand SAR during the
performance of this task.
Employees may voluntarily wear half-facepiece APRs with
PPublished by the Connecticut Department of Labor, Project Management Office0
cartridges when cleaning spray booth walls or changing booth filters and
half-facepiece APRs with organic vapor cartridges when loading coating agents
into supply systems. Although exposure monitoring has shown that exposures are
kept within PELs during these procedures, XYZ Seating will provide respirators
to workers who are concerned about potential exposures.
Updating the Hazard Assessment
The Program Administrator must revise and update the
hazard assessment as needed (i.e., any time work process changes may potentially
affect exposure). If an employee feels that respiratory protection is needed
during a particular activity, he/she is to contact his or her supervisor or the
Program Administrator. The Program Administrator will evaluate the potential
hazard, arranging for outside assistance as necessary. The Program Administrator
will then communicate the results of that assessment back to the employees. If
it is determined that respiratory protection is necessary, all other elements of
this program will be in effect for those tasks and this program will be updated
accordingly.
NIOSH Certification
All respirators must be certified by the National
Institute for Occupational Safety and Health (NIOSH) and shall be used in
accordance with the terms of that certification. Also, all filters, cartridges,
and canisters must be labeled with the appropriate NIOSH approval label. The
label must not be removed or defaced while it is in use.
Voluntary Respirator Use
XYZ Seating will provide respirators at no charge to
employees for voluntary use for the following work processes:
-
Employees may wear half-facepiece APRs with organic vapor
cartridges while working in the dip coat area.
-
Warehouse workers may wear filtering facepieces.
-
Spray Booth Operators may wear half-facepiece APRs with
organic vapor cartridges while cleaning spray guns.
-
Maintenance personnel may wear half-facepiece APRs with
PPublished by the Connecticut Department of Labor, Project Management Office0
cartridges while cleaning spray booth walls, and organic vapor cartridges while
loading spray guns.
The Program Administrator will provide all employees who
voluntarily choose to wear either of the above respirators with
a copy of Appendix D of the standard. (Appendix D details the
requirements for voluntary use of respirators by employees).
Employees choosing to wear a half-facepiece APR must comply with
the procedures for Medical Evaluation, Respirator Use, and
Cleaning, Maintenance and Storage.
The Program Administrator shall authorize voluntary use of
respiratory protective equipment as requested by all other workers on a
case-by-case basis, depending on specific workplace conditions and the results
of the medical evaluations.
Medical Evaluation
Employees who are either required to wear respirators, or
who choose to wear an APR voluntarily, must pass a medical exam before being
permitted to wear a respirator on the job. Employees are not permitted to wear
respirators until a physician has determined that they are medically able to do
so. Any employee refusing the medical evaluation will not be allowed to work in
an area requiring respirator use.
A licensed physician at BC medical clinic, where all
company medical services are provided, will provide the medical evaluations.
Medical evaluation procedures are as follows:
-
The medical evaluation will be conducted using the
questionnaire provided in Appendix C of the Respiratory Protection Standard. The
Program Administrator will provide a copy of this questionnaire to all employees
requiring medical evaluations.
-
To the extent feasible, the company will assist employees who
are unable to read the questionnaire (by providing help in reading the
questionnaire). When this is not possible, the employee will be sent directly to
the physician for medical evaluation.
-
All affected employees will be given a copy of the medical
questionnaire to fill out, along with a stamped and addressed envelope for
mailing the questionnaire to the company physician. Employees will be permitted
to fill out the questionnaire on company time.
-
Follow-up medical exams will be granted to employees as
required by the standard, and/or as deemed necessary by the ABC medical clinic
physician.
-
All employees will be granted the opportunity to speak with
the physician about their medical evaluation, if they so request.
-
The Program Administrator has provided the ABC medical clinic
physician with a copy of this program, a copy of the Respiratory Protection
Standard, the list of hazardous substances by work area, and for each employee
requiring evaluation: his or her work area or job title, proposed respirator
type and weight, length of time required to wear respirator, expected physical
work load (light, moderate, or heavy), potential temperature and humidity
extremes, and any additional protective clothing required.
-
Any employee required for medical reasons to wear a positive
pressure air purifying respirator will be provided with a powered air purifying
respirator.
-
After an employee has received clearance and begun to wear
his or her respirator, additional medical evaluations will be provided under the
following circumstances:
- Employee reports signs and/or symptoms related to their
ability to use a respirator, such as shortness of breath, dizziness, chest
pains, or wheezing.
- The ABC medical clinic physician or supervisor informs the
Program Administrator that the employee needs to be reevaluated;
-
Information from this program, including observations made
during fit testing and program evaluation, indicates a need for reevaluation;
- A change occurs in workplace conditions that may result in an
increased physiological burden on the employee.
A list of XYZ Seating employees currently included in medical
surveillance is provided in Table 2 of this program.
All examinations and questionnaires are to remain
confidential between the employee and the physician.
Fit Testing
Fit testing is required for employees wearing
half-facepiece APRs for exposure to wood dust in Prep and Assembly, and
maintenance workers who wear a tight-fitting SAR for dip tank cleaning.
Employees voluntarily wear half-facepiece APRs may also be fit tested upon
request.
Employees who are required to wear half-facepiece APRs
will be fit tested:
-
Prior to being allowed to wear any respirator with a tight
fitting facepiece.
-
Annually.
-
When there are changes in the employee's physical condition
that could affect respiratory fit (e.g., obvious change in body weight, facial
scarring, etc.).
Employees will be fit tested with the make, model, and size
of respirator that they will actually wear. Employees will be
provided with several models and sizes of respirators so that
they may find an optimal fit. Fit testing of PAPRs is to be
conducted in the negative pressure mode.
The Program Administrator will conduct fit tests following
the OSHA approved Bitrex Solution Aerosol QLFT Protocol in Appendix B (B4) of
the Respiratory Protection Standard.
The Program Administrator has determined that QNFT is not
required for the respirators used under current conditions at XYZ Seating. If
conditions affecting respirator use change, the Program Administrator will
evaluate on a case-by-case basis whether QNFT is required.
Respirator Use
Respiratory protection is required for the following
personnel:
| TABLE 2: XYZ Seating
Personnel in Respiratory Protection Program |
| Name |
Department |
Job Description/
Work Procedure |
Respirator |
| Joe Apple |
Prep |
Operator |
Half mask APR PPublished by the Connecticut Department of
Labor, Project Management Office0 filter when sanding/
SAR continuous flow hood for cleaning |
| Ron Carey |
Maintenance |
Dip tank cleaning |
SAR, pressure demand with auxiliary SCBA |
| Lisa Jones |
Coating |
Spray Booth Operator |
SAR, continuous flow hood |
General Use Procedures:
-
Employees will use their respirators under conditions
specified by this program, and in accordance with the training they receive on
the use of each particular model. In addition, the respirator shall not be used
in a manner for which it is not certified by NIOSH or by its manufacturer.
-
All employees shall conduct user seal checks each time that
they wear their respirator. Employees shall use either positive or negative
pressure check (depending on which test works best for them) specified in
Appendix B-1 of the Respiratory Protection Standard.
-
All employees shall be permitted to leave the work area to go
to the locker room to maintain their respirator for the following reasons: to
clean their respirator if the respirator is impeding their ability to work,
change filters or cartridges, replace parts, or to inspect respirator if it
stops functioning as intended. Employees should notify their supervisor before
leaving the area.
-
Employees are not permitted to wear tight-fitting respirators
if they have any condition, such as facial scars, facial hair, or missing
dentures, that prevents them from achieving good seal. Employees are not
permitted to wear headphones, jewelry, or other articles that may interfere with
the facepiece-to-face seal.
Emergency Procedures:
The following work areas have been identified as having
foreseeable emergencies:
- Spray Booth Cleaning Area - spill of
hazardous waste
- Dip Coat Area - malfunction of ventilation system, leak in
supply system
- Coatings Storage Area - spill or leak of hazardous substances
When the alarm sounds, employees in the affected
department must immediately don their emergency escape respirator, shut down
their process equipment, and exit the work area. All other employees must
immediately evacuate the building. XYZ Seating's Emergency Action Plan describes
these procedures (including proper evacuation routes and rally points) in
greater detail.
Emergency escape respirators are located:
-
Locker #1 in the Spray Booth Area
-
Storage Cabinet #3 in Dip Coat/Drying Area
-
Locker #4 in the Coatings Storage Area
Respiratory protection in these instances is for escape
purposes only. XYZ Seating employees are not trained as
emergency responders, and are not authorized to act in such a
manner.
Respirator Malfunction
- APR Respirator Malfunction:
For any malfunction of an APR (e.g., such as breakthrough,
facepiece leakage, or improperly working valve), the respirator wearer should
inform his or her supervisor that the respirator no longer functions as
intended, and go to the designated safe area to maintain the respirator. The
supervisor must ensure that the employee receives the needed parts to repair the
respirator, or is provided with a new respirator.
All workers wearing atmosphere-supplying respirators will
work with a buddy. Buddies shall assist workers who experience an SAR
malfunction as follows:
If a worker in the spray booth experiences a malfunction
of an SAR, he or she should signal to the buddy the he or she has had a
respirator malfunction. The buddy shall don an emergency escape respirator and
aid the worker in immediately exiting the spray booth.
Workers cleaning wood pieces or assembled furniture in the
Prep department will work with a buddy. If one of the workers experiences a
respirator malfunction, he or she shall signal this to their buddy. The buddy
must immediately stop what he or she is doing to escort the employee to the Prep
staging area where the employee can safely remove the SAR.
IDLH Procedures
The Program Administrator has identified the following
area as presenting the potential for IDLH conditions:
Dip Coat Tank Cleaning
Maintenance workers will be periodically required to enter
the dip tank to perform scheduled or unscheduled maintenance. In such cases,
workers will follow the permit required confined space entry procedures
specified in the XYZ Seating Confined Space Program. As specified in these
procedures, the Program Administrator has determined that workers entering this
area shall wear a pressure demand SAR. In addition, an appropriately trained and
equipped standby person shall remain outside the dip tank and maintain constant
voice and visual communication with the worker. In the event of an emergency
requiring the standby person to enter the IDLH environment, the standby person
shall immediately notify the Program Administrator and will proceed with rescue
operations in accordance with rescue procedures outlined in the XYZ Seating
Confined Space Program.
Air Quality
For supplied-air respirators, only Grade D breathing air
shall be used in the cylinders. The Program Administrator will coordinate
deliveries of compressed air with the company's vendor, Compressed Air, Inc.,
and require Compressed Air, Inc. to certify that the air in the cylinders meets
the specifications of Grade D breathing air.
The Program Administrator will maintain a minimum air
supply of one fully charged replacement cylinder for each SAR unit. In addition,
cylinders may be recharged as necessary from the breathing air cascade system
located near the respirator storage area. The air for this system is provided by
XYZ Seating's supplier, and deliveries of new air are coordinated by the Program
Administrator.
Cleaning, Maintenance, Change
Schedules and Storage
Cleaning
Respirators are to be regularly cleaned and disinfected at
the designated respirator cleaning station located in the employee locker room.
Respirators issued for the exclusive use of an employee
shall be cleaned as often as necessary, but at least once a day for workers in
the Prep and Assembly departments.
Atmosphere supplying and emergency use respirators are to
be cleaned and disinfected after each use.
The following procedure is to be used when cleaning and
disinfecting respirators:
-
Disassemble respirator, removing any filters, canisters, or
cartridges.
-
Wash the facepiece and associated parts in a mild detergent
with warm water. Do not use organic solvents.
-
Rinse completely in clean warm water.
-
Wipe the respirator with disinfectant wipes (70% Isopropyl
Alcohol) to kill germs.
-
Air dry in a clean area.
-
Reassemble the respirator and replace any defective parts.
-
Place in a clean, dry plastic bag or other air tight
container.
Note: The Program Administrator will ensure an adequate supply of
appropriate cleaning and disinfection material at the cleaning
station. If supplies are low, employees should contact their
supervisor, who will inform the Program Administrator.
Maintenance
Respirators are to be properly maintained at all times in
order to ensure that they function properly and adequately protect the employee.
Maintenance involves a thorough visual inspection for cleanliness and defects.
Worn or deteriorated parts will be replaced prior to use. No components will be
replaced or repairs made beyond those recommended by the manufacturer. Repairs
to regulators or alarms of atmosphere-supplying respirators will be conducted by
the manufacturer.
The following checklist will be used when inspecting
respirators:
- Facepiece:
-
cracks, tears, or holes
-
facemask distortion
-
cracked or loose lenses/faceshield
- Headstraps:
-
breaks or tears
-
broken buckles
-
Valves:
-
residue or dirt
-
cracks or tears in valve material
- Filters/Cartridges:
- approval designation
- gaskets
- cracks or dents in housing
- proper cartridge for hazard
- Air Supply Systems:
- breathing air quality/grade
- condition of supply hoses
- hose connections
- settings on regulators and valves
Employees are permitted to leave their work area to
perform limited maintenance on their respirator in a designated area that is
free of respiratory hazards. Situations when this is permitted include to wash
their face and respirator facepiece to prevent any eye or skin irritation, to
replace the filter, cartridge or canister, and if they detect vapor or gas
breakthrough or leakage in the facepiece or if they detect any other damage to
the respirator or its components.
Change Schedules
Employees wearing APRs or PAPRs with PPublished by the
Connecticut Department of Labor, Project Management Office0 filters for
protection against wood dust and other particulates shall change the cartridges
on their respirators when they first begin to experience difficulty breathing
(i.e., resistance) while wearing their masks.
Based on discussions with our respirator distributor about
XYZ Seating's workplace exposure conditions, employees voluntarily wearing APRs
with organic vapor cartridges shall change the cartridges on their respirators
at the end of each work week to ensure the continued effectiveness of the
respirators.
Storage
Respirators must be stored in a clean, dry area, and in
accordance with the manufacturer's recommendations. Each employee will clean and
inspect their own air-purifying respirator in accordance with the provisions of
this program and will store their respirator in a plastic bag in their own
locker. Each employee will have his/her name on the bag and that bag will only
be used to store that employee's respirator.
Atmosphere supplying respirators will be stored in the
storage cabinet outside of the Program Administrator's office.
The Program Administrator will store XYZ's supply of
respirators and respirator components in their original manufacturer's packaging
in the equipment storage room.
Defective Respirators
Respirators that are defective or have defective parts
shall be taken out of service immediately. If, during an inspection, an employee
discovers a defect in a respirator, he/she is to bring the defect to the
attention of his or her supervisor. Supervisors will give all defective
respirators to the Program Administrator. The Program Administrator will decide
whether to:
-
Temporarily take the respirator out of service until it can
be repaired.
-
Perform a simple fix on the spot such as replacing a
headstrap
-
Dispose of the respirator due to an irreparable problem or
defect.
When a respirator is taken out of service for an extended
period of time, the respirator will be tagged out of service,
and the employee will be given a replacement of similar make,
model, and size. All tagged out respirators will be kept in the
storage cabinet inside the Program Administrator's office.
Training
The Program Administrator will provide training to
respirator users and their supervisors on the contents of the XYZ Seating
Respiratory Protection Program and their responsibilities under it, and on the
OSHA Respiratory Protection Standard. Workers will be trained prior to using a
respirator in the workplace. Supervisors will also be trained prior to using a
respirator in the workplace or prior to supervising employees that must wear
respirators.
The training course will cover the following topics:
-
the XYZ Seating Respiratory Protection Program
-
the OSHA Respiratory Protection Standard
-
respiratory hazards encountered at XYZ Seating and their
health effects
-
proper selection and use of respirators
-
limitations of respirators
-
respirator donning and user seal (fit) checks
-
fit testing
-
emergency use procedures
-
maintenance and storage
-
medical signs and symptoms limiting the effective use of
respirators
Employees will be retrained annually or as needed (e.g., if
they change departments and need to use a different respirator).
Employees must demonstrate their understanding of the topics
covered in the training through hands-on exercises and a written
test. Respirator training will be documented by the Program
Administrator and the documentation will include the type,
model, and size of respirator for which each employee has been
trained and fit tested.
5.0 Program
Evaluation
The Program Administrator will conduct periodic
evaluations of the workplace to ensure that the provisions of this program are
being implemented. The evaluations will include regular consultations with
employees who use respirators and their supervisors, site inspections, air
monitoring and a review of records.
Problems identified will be noted in an inspection log and
addressed by the Program Administrator. These findings will be reported to XYZ
Seating management, and the report will list plans to correct deficiencies in
the respirator program and target dates for the implementation of those
corrections.
6.0
Documentation and Recordkeeping
A written copy of this program and the OSHA standard is
kept in the Program Administrator's office and is available to all employees who
wish to review it.
Also, maintained in the Program Administrator's office are
copies of training and fit test records. These records will be updated as new
employees are trained, as existing employees receive refresher training, and as
new fit tests are conducted.
The Program Administrator will also maintain copies of the
medical records for all employees covered under the respirator program. The
completed medical questionnaire and the physician's documented findings are
confidential and will remain at ABC Medical Clinic. The company will only retain
the physician's written recommendation regarding each employee's ability to wear
a respirator.
TABLE 3: XYZ SEATING HAZARD ASSESSMENT - JUNE 1998
| Department |
Contaminants |
Exposure Level
(8 hrs. TWA)* |
PEL |
Controls |
| Prep : Sanding |
wood dust |
2.5 - 7.0
mg/m3 |
5 mg/m3
(TLV = 1 mg/m3) |
Local exhaust ventilation (LEV) for sanders.
Half-facepiece APR with P0 filter. |
| Prep : Cleaning |
methylene chloride |
70 ppm |
25 ppm
125 ppm - STEL |
LEV to be installed for cleaning
stations. Continuous flow SAR hood until then needed for respiratory protection.
Will reevaluate after LEV installation. |
| methanol |
150 ppm |
200 ppm |
| acetone |
400 ppm |
1,000 ppm |
| Coating: Spray booth
painting |
toluene |
(300 ppm)** |
200 ppm
500 ppm = min peak |
Continuous flow SAR hood. |
| xylene |
(40 ppm)** |
0 ppm
150 ppm = STEL |
| MEK (methyl ethyl ketone) |
(25 ppm)** |
200 ppm |
| methanol |
(20 ppm)** |
200 ppm |
TABLE 3: XYZ SEATING HAZARD ASSESSMENT - JUNE 1998
(continued)
| Department |
Contaminants |
Exposure Level
(8 hrs. TWA)* |
PEL |
Controls |
| Coating: Spray booth gun
cleaning |
toluene |
80 ppm (30 min) |
200 ppm
500 ppm = min peak |
Half-facepiece APR with organic
vapor cartridge |
| methanol |
300 (30 min) |
200 ppm |
| Coating: Dip Coat |
toluene |
25 ppm |
200 ppm
500 ppm = min peak |
Automated line is vented. Workers
may voluntarily wear half-facepiece APR with organic vapor cartridge. |
| xylene |
50 ppm |
0 ppm
150 ppm = STEL |
| MEK |
60 ppm |
200 ppm |
| MIBK |
ppm |
0 ppm |
| methanol |
50 ppm |
200 ppm |
| Drying (oven) |
None (monitoring revealed no significant
exposures) |
NA |
NA |
NA |
| Assembly : Sanding, gluing
and nailing |
wood dust |
2.5 - 6.0 mg/m3 |
5 mg/m3
(TLV = 1 mg/m3) |
Aqueous-based glues will be used
to eliminate exposures to methylene chloride, formaldehyde and epichlorohydrin |
| formaldehyde |
1.0 ppm |
0.75 ppm
2 ppm = STEL |
| epichlorohydrin |
4 ppm |
5 ppm |
| methylene chloride |
60 ppm |
25 ppm
125 = STEL |
TABLE 3: XYZ SEATING HAZARD ASSESSMENT - JUNE 1998
(continued)
| Department |
Contaminants |
Exposure Level
(8 hrs. TWA)* |
PEL |
Controls |
| Maintenance: Dip Tank |
toluene, xylene, MEK, MIBK, methanol |
IDLH conditions |
|
SAR, pressure demand with auxiliary SCBA must
be worn |
| Maintenance: Spray booth
cleaning/filter change |
particulate |
1.8 mg/m3 |
5 mg/m3 |
Voluntary use, half-facepiece APR with
P0
filter |
| Maintenance: Loading
coatings into supply systems |
toluene |
40 ppm (1 hr) |
200 ppm
500 ppm = min peak |
Voluntary use, half-facepiece APR
with organic vapor cartridges |
| xylene |
80 ppm (1 hr) |
0 ppm
150 ppm = STEL |
| MEK |
Published by the Connecticut Department of
Labor, Project Management Office0 ppm (1 hr) |
200 ppm |
| MIBK |
15 ppm (1 hr) |
0 ppm |
| methanol |
125 ppm (1 hr) |
200 ppm |
| Warehouse |
None |
NA |
NA |
NA |
* Summarized from Industrial Hygiene report provided by
ABC Industrial Hygiene Services
** These values were obtained from a survey on average
exposures in downdraft spray booths utilized in the furniture coating industry
as published in the American Journal of Industrial Hygiene
___________________________ .
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