Respiratory Protection Program

This program applies to all Miami University employees performing the aforementioned routine tasks who are required to wear a respirator. This includes employees in the Environmental Health and Safety Offices, Physical Facilities Department, and the Department of Recreational Sports. Employees performing these tasks in these areas shall comply with all provisions of this Respiratory Protection Program.  Additionally, employees who voluntarily use a respirator when respiratory protection is not required shall comply with selected provisions of this program, to include medical evaluations, cleaning, maintenance, and storage of respirators.  The employee shall be responsible for providing their own respirator, with prior approval by EHSO. The voluntary use of filtering face-pieces (i.e., dust masks) is not addressed in this program.  Respirators shall be provided by Miami University (i.e., the affected department) when such equipment is necessary to protect the health of the employee.  Respirators shall be provided to employees who have had medical surveillance, training, and fit testing for the purpose intended. The expense associated with employee training and medical evaluations shall be the responsibility of the department. The Required Respirators page outlines the required respirator and associated task or process for each department, and also addresses voluntary respirator use.

Program Administrator

EHSO is responsible for administering the Respiratory Protection Program. Responsibilities include:

• Conducting audits of the workplace and processes to determine if respiratory protection is necessary (i.e., personal exposure monitoring), when engineering controls are not feasible.
• Selecting the proper respiratory protection.
• Auditing affected departments to ensure compliance with the Respiratory Protection Program.
• Administering the medical surveillance program.
• Maintaining records required by the program.
• Evaluating and updating the program, when necessary.

Supervisors

Affected department’s supervisors shall make this document readily accessible to employees or their representatives through posting, inserting in a departmental procedures manual, or by providing photocopies upon request. The master copy shall be on file in EHSO. In addition, the supervisor is responsible for the following:

• Understanding the requirements of the program.
• Ensuring that employees receive annual training, fit testing, and medical evaluations.
• Providing the appropriate respiratory equipment (i.e., through the Program Administrator).
• Ensuring that employees understand and comply with the program. This includes proper use, care, and, maintenance.
• Understanding which processes require the use of respiratory protection.

Employees

The employee shall use respirators according to instructions and training received. Employees are responsible for the following:

• Care and maintenance of respirators.
• Notifying their supervisor if the respirator no longer fits properly. This could occur if there is a substantial weight loss or gain, or a change in facial configuration.
• Informing their supervisor or EHSO of any concerns they have with the program.

Occupational Safety and Health Administration Code of Federal Regulations, Chapter 29, Part 1910, Section 134, “Respiratory Protection.” (29 CFR 1910.134)

EHSO shall review the Respiratory Protection Program at least annually to ensure departments and affected employees are supporting and following the requirements herein. This may include inspections of respirators used, maintenance records, and real-time industrial hygiene sampling. Only EHSO can add, delete, or modify any provisions in this program.

EHSO will evaluate or coordinate the evaluation of the respiratory hazard(s) of each workplace, process, or work area where airborne contaminants may be present. The hazard evaluation will include:

• Identification of potentially hazardous contaminants used in the workplace.
• Evaluation of the work process to determine potential exposure to the hazardous contaminants. The evaluation will include observation of the work process, employee interviews, and workplace or user factors (e.g., temperature, humidity, and workload).
• Personal exposure monitoring to quantify employee exposure. This monitoring will be conducted by EHSO when feasible. The results of the current hazard evaluation are as follows:
  • Asbestos Operations: In accordance with 29 CFR 1926.1101, respiratory protection is required during Class I, II, and III asbestos operations. Half-face APRs with P100 filters are required for employees performing these duties. Full-face PAPRs also are available for employees when exposures exceed 1 fiber per cubic centimeter (f/cc).
  • Asbestos Removal Oversite: Respiratory protection is required for employees conducting asbestos monitoring in Regulated areas, per 29 CFR 1926.1101. Half-face APRs and full-face APRs equipped with P100 filters are the required protection.
  • Pesticide/Herbicide Application: Grounds employees apply various types of liquid and dry pesticides and herbicides to University grounds. Because the application of these materials is performed outside, exposure potential is anticipated to be low. However; employees continue to use half-face APRs equipped with organic vapor cartridges during specific tasks (e.g., material mixing, downwind application). Pesticide application is routinely performed by Pest Control (PFD) employees throughout University buildings, to control the insect population. Various types of liquid and dry pesticides are applied. Potential exposure could occur during the mixing and application of these products. In 1998, air monitoring was conducted during the use of pyrethrum for fly treatment. Results showed exposures below the OSHA PEL.
  • Hazardous Residual Handling: Employees in EHSO are potentially exposed to airborne concentrations of solvents, corrosives, and toxins during University waste stream minimization. This bulking process is performed at the Hazardous Residuals Facility either outside or in proximity to the fume hood, located inside B Building. As a precaution, full-face APR’s with combination cartridges are being used during this process.
  • Pool Chemical Handling Operations: Recreational Sports Center employees are potentially exposed to hydrochloric acid mists during pool maintenance activities. A full-face APR equipped with chemical cartridges is required. 
  • Boiler Maintenance Activities: Steam Plant employees routinely perform Boiler maintenance activities in confined spaces. Employees are potentially exposed to respirable dust above the PEL. Full-face APRs equipped with P100 filters are used during this task.

EHSO shall repeat the hazard evaluation when necessary. This includes changes in the work process (i.e., engineering or administrative controls), or product. When employees feel that respirators may be necessary for a task, a baseline hazard assessment shall be accomplished, the results of which shall be communicated to the employee. New work processes or tasks will be added to this Respiratory Protection Program when it is determined that respirators are necessary, based on the results of the hazard evaluation.

Employees shall be responsible for providing their own respirator, with prior approval by EHSO. The Program Administrator will provide employees who use respirators on a voluntary basis a copy of Appendix D of OSHA’s Respiratory Protection Standard. Employees choosing to war a half-face APR shall comply with the Medical Evaluation, Respiratory Use, and Cleaning, Maintenance and Storage provisions of this program.

Employees shall not be assigned to tasks requiring the use of respirators or allowed to wear APRs voluntarily unless it has been determined that they are physically able to perform the work and use the respiratory protective device. Any employee refusing the medical evaluation will not be allowed to work in an area requiring the use of a respirator. This medical evaluation shall be performed by a physician or other licensed health care professional (PLHCP). The medical evaluation procedures are as follows:

• The medical questionnaire found in Appendix C, 29 CFR 1910.134. A copy of the questionnaire will be provided by Miami University’s Program Administrator. When an employee is not capable of reading or understanding the medical questionnaire, Miami University will send the employee directly to the PLHCP for medical evaluation.
• After completing the medical questionnaire, the employee will mail it to PLHCP in a stamped and addressed envelope provided by Miami University. The employee will be allowed to complete the questionnaire during work hours.
• Miami University shall ensure that a follow-up medical examination is provided depending upon the results of the medical evaluation or where the initial medical examination demonstrates the need for a follow-up examination. PLHCP will determine those employees requiring follow-up examinations. The follow-up medical examination shall include any medical tests, consultations, or diagnostic procedures that the PLHCP deems necessary to make a final determination.
• All employees will be given the chance to speak with the physician at PLHCP about the results of their medical evaluation, if so requested.
• Miami University has provided a copy of the Respiratory Protection Program to PLHCP.

At a minimum, Miami University will provide additional medical evaluations under the following circumstances:

• An employee reports medical signs or symptoms that are related to his/her ability to use a respirator, PLHCP, the employee’s supervisor, or the Program Administrator feels the employee needs to be re-evaluated
• Information from the Respiratory Protection Program, to include observations made during fit testing and routine program evaluations indicate a need for employee reevaluation.
• A change occurs in workplace conditions (e.g., physical work effort, protective clothing, and temperature) that may result in an additional increase on employee burden.

Prior to Miami University employees using a negative or positive pressure tightfitting respirator (where respiratory protection is required), a quantitative fit test must be performed to determine adequacy of a face to face-piece seal. Employees voluntarily wearing half-face APRs may also be fit tested upon request. The employee must be fit tested with the same make, model, style, and size of respirator that will be used. Employees will be provided with several models and sizes or respirators so that they may choose a comfortable fit. Fit testing will be conducted per the following schedule:

• Prior to initial use.
• Whenever a different respirator face-piece is used.
• Whenever physical conditions change ( e.g., change in body weight, facial scarring), affecting seal.
• At least annually.

The Program Administrator will perform employee fit testing per the OSHA accepted protocol (Appendix A, 29 CFR 1910.134) using irritant smoke. All tightfitting atmosphere supplying and powered air-purifying respirators will be fit tested in the negative pressure mode.

General Use Procedures

• To assure proper protection, employees will check the face-piece fit every time the respirator is put on. This will be accomplished by performing a positive or negative pressure fit check (depending on which test works best), specified in Appendix B-1 of the Respiratory Protection Standard.
• Respirators shall not be worn when conditions prevent a good face seal. For example, facial hair, facial scars, sideburns, temple pieces on glasses, missing dentures, or other articles that prevent a good seal. Special precautions need to be implemented for employees who wear corrective glasses and a full-face respirator. A proper seal cannot be established if the temple bars of eye glasses extend through the sealing edge of the full face-piece. Systems have been developed for mounting corrective lenses inside full face-pieces. The use of contact lenses inside full-face respirators is permitted. To assure proper protection, the face-piece fit shall be checked by the wearer each time he/she puts on the respirator by following the face-piece fitting instructions.
• Supervisors shall ensure that employees leave the respirator use area as follows: to wash their face and respirator often to prevent skin irritation associated with respirator use; change filters or cartridges; replace parts; or to inspect respirator if it no longer functions properly.
• Employee work area conditions will be frequently monitored by supervisory personnel to ensure that the Respiratory Protection Program is adhered to. Employees will use respirators under conditions specified by the Respiratory Protection Program and in accordance with training received.

Respirator Malfunction

For any malfunction of a respirator (e.g., breakthrough, face-piece leakage, etc.), the employee should inform their supervisor that the respirator no longer functions as intended. The employee shall go to a designated safe area to repair the respirator.

Respirators for IDLH Atmospheres

Entry into all IDLH atmospheres is prohibited.

Respirator Maintenance and Care

Maintenance of respirators shall be adjusted to the type of working conditions and hazards involved. Therefore, the maintenance schedule for respirators used infrequently will not be as rigorous as for respirators used more often (e.g., weekly).  Maintenance of respirators shall include inspections for defects and cleanliness.  The inspection shall be made by the user to locate any worn, damaged, or deteriorated parts. The following outlines the respirator inspection schedule:

• All respirators shall be inspected routinely before and after each use by the user. A respirator that is not routinely used shall be inspected before and after each use and at least monthly to assure that it is in satisfactory working condition.
• Disassemble respirator, removing the cartridge or filter.
• Wash the face-piece and associated parts in a mild detergent with warm water. Do not use solvent.
• Rinse completely with warm water.
• Wipe the respirator with disinfectant wipes (alcohol wipes) to kill germs.
• Air dry in a clean area by placing respirator on a clean paper towel.
• Reassemble the respirator.

Respirators shall be stored in a convenient, clean, and sanitary condition.  Respirators shall be placed in designated areas in a sealed carrying case or plastic bag. After inspection, cleaning, and necessary repair, respirators shall be stored to protect against dust, sunlight, heat, extreme cold, excessive moisture, or damaging chemicals. Respirators shall be packed or stored so that the face-piece and exhalation valve will rest in a normal position and function will not be impaired by the elastomer setting in an abnormal position.

Filter and Cartridge Change Schedule

End-of-service-life indicators currently do not exist. Until ESLI’s are incorporated by the manufacturers, experience and professional judgment shall be used to determine the appropriate change schedule. Employees wearing APRs or PAPRs with P100 filters for protection against
particulates or fibers shall change filters when they begin to experience breathing resistance. Employees using APRs and PAPRs with chemical cartridges shall change cartridges on their respirators at the end of each work week (when the respirator is used on a routine basis) to ensure effectiveness of the respirator cartridge.

NIOSH Certification

Only respirators approved by the National Institute for Occupational Safety and Health (NIOSH) will be used, regardless of whether the respirator is required or used voluntarily. In addition, all filters, cartridges, and canisters must be labeled with the appropriate NIOSH label. Each cartridge shall be painted a distinctive color or combination of colors indicated.  All colors used shall be such that they are clearly identifiable by the user and clearly distinguishable from one another. The color coating used shall offer a high degree of resistance to chipping, scaling, peeling, blistering, fading, and the effects of the ordinary atmospheres to which they may be exposed under normal conditions of storage and use. Appropriately colored pressure sensitive tape may be used for the stripes.

Important: Gray shall not be assigned as the main color for a cartridge designed to remove acids or vapors. Orange shall be used as a complete body, or stripe color to represent gases not included in this table. The user will need to refer to the cartridge label to determine the degree of protection the cartridge will afford.

Training

All respirator users will be instructed in respiratory protection and trained in the proper selection, use, and maintenance of a respirator. In addition, the user shall be instructed and trained in the proper use of respirators and their limitations.  Instruction and training will be conducted by EHSO and HTI, Inc. to supervisors and employees annually or as needed upon written request or whenever there is reason to believe that the respiratory protection program may no longer be adequately protecting employees. Voluntary respirator users will be provided the basic information on respirators, as outlined in Appendix D, 29 CFR 1910.134.  Training shall provide the employees an opportunity to handle the respirator, have it fitted properly, test its face-piece-to-face seal, wear it in normal air for a long familiarity period, and to wear it in a test atmosphere. Employees will be retrained annually or as needed.  Every employee required to wear a respirator shall receive fitting instructions including demonstrations and practice in how the respirator should be worn, how to adjust it, and how to determine if it fits properly. Following training, employees must be capable of demonstrating knowledge of at least the following elements:

• Why respirators are necessary and why improper fit, usage, or maintenance can compromise its effectiveness;
• Respirator limitations;
• Proper use of respirators in emergency situations;
• How to recognize medical signs and symptoms that may limit or prevent the effective use of a respirator; and
• The general requirements of the Respiratory Protection Program.

Regular evaluations of the workplace shall be performed to ensure that the Respiratory Protection Program is being properly implemented, and to consult employees to ensure that they are using the respirators properly. The evaluations shall be conducted by EHSO and supervisory personnel.

A written copy of this program and the OSHA standard is kept in the Program Administrator’s office and is available to all Miami University employees. The Program Administrator also maintains records of employee quantitative fit testing and employee respirator training.
Medical records are maintained by Miami University’s Student Health Center. This includes the employee’s medical history, pulmonary function tests, chest X-ray, and EKG results. EHSO shall only retain the physician’s written opinion regarding each employee’s ability to wear a respirator.