Consider Henry, an operations manager in Philadelphia. For him, the purpose of training is getting workers to fill out the right forms. He has achieved his goal when his filing cabinet is full of certifications, all formatted so the OSHA inspector has easy access to the records of every employee in his company.
Or consider Jane, a risk manager in Portland. For her, training is conducted so she can provide tangible evidence to her legal department. With an Excel spreadsheet at the ready, Jane's task of controlling liability has been accomplished.
Henry and Jane both mean well, but their training programs are failures because they stem from the wrong motivation. In the end, neither manager knows if their employees are adequately trained. Their approaches are a caricature of good safety management.
Forms and spreadsheets are not in themselves proof of effective training. A genuine respiratory protection program depends on proper training, not paper trails. Employees should not be trained to keep OSHA happy. Nor should they be trained with legal liability as a priority. No doubt these are desirable consequences of proper training, but the overriding purpose of responsible training is to ensure the health and safety of workers who wear respirators.
OSHA Standard 1910.134 requires that where respirators are necessary to protect the health of the employee, the employer shall implement a respiratory protection program. This program must include training employees in the proper use of respirators, including instruction for putting them on and removing them, as well as providing information about capabilities and limitations.
Three Phases of Training
For training to be effective, three distinct phases must be completed with the welfare of the worker first and foremost.
Phase One: Focus on the primary purpose of the training.
Best practice ensures the health and safety of workers who wear respirators. Any other benefit obtained is secondary to safety. It is self-serving for businesses to focus on avoiding liability lawsuits, avoiding OSHA fines or trying to keep OSHA at bay.
When workers are safe and healthy, secondary purposes are achieved, but putting secondary purposes first is a bad, if not dangerous, practice.
Phase Two: Develop the training framework.
Best practice treats trainees as capable, responsible people, with qualified and committed trainers explaining the use of respiratory protection in real circumstances and offering solutions to potential problems.
Employers should refrain from treating trainees like children and imposing procedures in an arbitrary manner. Respirator training is an adult learning activity. Adults learn best when the practical benefits of what they are taught are clearly explained. Site-specific conditions should be demonstrated and specific protection practices reinforced. Employers should develop a training framework to support such instruction.
Phase Three: Implement contextualized training.
Best practice makes training relevant and takes into account specific work conditions. It is careless to generalize training so that it has no specific meaning or value to the worker.
Timing is critical when it comes to training. A conscientious employer should complete respirator training before the worker uses the device on the job. Respirator training should not take place on the job, where it's likely to compete with other responsibilities for the worker's attention.
Workers must be fully aware of the risks they face in their workplace, and understand that respirators are provided for their safety. When workplace hazards are divulged and relevant facts disclosed, employees become participants in their own safety program.
Employers should explain the capabilities and limitations of respirators. It is negligent for employers to select a specific type of respirator and impose its use without explaining why it is the right product for a specific environment. Users must be able to relate the performance of the respirator to the hazards that they face in their own circumstances.
Different grades of respirators have different capabilities. It is important that users understand when and where it is suitable to use a mask like an N95 and when it is necessary to use respirators that provide greater protection such as battery-powered air purifiers, supplied-air respirators or self-contained breathing apparatus. The user must be taught the capabilities and the limitations of a selected respirator, so the reason for its selection is declared and justified.
Employers should explain how to inspect and test respirators. Users must understand what makes the respirator function correctly, and what procedures are in place to make sure it is performing correctly when it is worn. The employer must not lead workers to believe they are protected when in fact they are not. Not teaching workers how to inspect the respirator may easily cause this to happen.
Every worker who may wear a respirator must be personally trained, with the most important element of the training occurring when the worker wears the respirator and experiences the feel and the fit. For half-mask respirators, the wearer needs to be shown how to adjust the straps and check for an adequate fit. More complex products such as battery-powered respirators need more comprehensive pre-use familiarization. The user must be shown how to wear the battery and the blower, and how to don the hood safely. The trainer must demonstrate this, then the trainee must duplicate it and wear the respirator until he can confidently put it on, take it off and understand how it feels when being worn. There is no substitute for this. A worker who has not physically experienced the respirator cannot be regarded as fully trained in its use.
Businesses must make certain that all workers are fit tested. OSHA standards contain details of accepted fit-test methods, specifying that an appropriate qualitative or quantitative fit test must be implemented. Users must be fit tested before initial use, whenever a different respirator facepiece is used and at least once a year thereafter. Refitting is also indicated if a worker's physical condition changes in a way that might affect fit. Many different factors may affect how a respirator fits and therefore how well it protects. These factors include variations in body weight, growing a beard, starting to wear eyeglasses or the debilitating effects of an illness. Loose fitting respirators, such as battery-powered or supplied-air respirators with hoods, do not require fit testing.
Employers should heed maintenance and storage procedures. Employees must be taught their safety can be compromised when respirators are not maintained and stored correctly. Masks must be cleaned and disinfected to avoid the risk of infection. Filters must be changed so that users do not depend on filters that are beyond their useful life. Components such as valves, flaps and, when incorporated, batteries, blowers and all other parts of the system, must be inspected to make sure they are working correctly. Nobody must ever wear a respirator that is not appropriate, clean, complete and working as required.
Respirator users should be given the opportunity to review the manufacturer's instruction book. The instruction book must be part of the training curriculum. It contains important information about the respirator, including warnings, limitations on use, maintenance and cleaning directions.
Best practice encourages training for emergency events. The possibility of emergency must influence the choice of respirator. It is too late to upgrade a respirator in use when an emergency is occurring. Take, for example, a scenario where a worker is normally exposed to a very low level of chlorine, but there is the foreseeable chance that he may be exposed to a higher level in an emergency. Such risk must be explained to the worker and a higher-grade product should be used. If overexposure is a very serious hazard, the user should wear a higher-grade respirator routinely. For example, a worker overexposed to isocyanates may suffer serious harm. These substances are very toxic and have very poor warning properties, so a worker does not know when he is overexposed. When the workplace contains such substances, it is good practice to use higher-grade protection such as supplied-air respirators. When the site-specific evaluation identifies the need for escape respirators for emergencies, they must be provided and workers fully trained in their use. It is a common error to miss training workers on emergency respirators. The result is that when an emergency occurs, workers do not know how to react and their immediate danger is increased.
Only the qualified need be engaged in respirator training. Trainers should be certified safety and health professionals or authorized representatives of the respirator manufacturer. Employee safety and confidence is paramount to business. Using unqualified trainers is a clear indication that the training sessions are a sham, and as such, an insult to workers.
Recognize achievement by awarding certificates to workers who complete training. At the end of the training, each participant should complete a sheet of questions designed to verify that the course material has been understood. The trainer should review the answers and address any areas of weakness. Maintain training data and record attendees' names in the file intended for the OSHA inspector. Certification is an important conclusion to any adult learning experience. Acknowledgement of participation instills a sense of achievement and encourages workers to support the training.
Once a best practices respirator training program has been established, schedule a retraining session at least once year. Retraining refreshes information, reinforces the importance of the program and takes into account new and changed circumstances.
Lastly, employers must ensure that comprehensive OSHA standards and all other applicable regulations are incorporated into the respirator program. Above all else, employers should remember that cutting corners creates risk. Expressed simply, the primary purpose of respirator training is the safety of workers.
Kenneth Vaughan is president and CEO of Neoterik Health Technologies, a manufacturer of respiratory and professional safety equipment since 1981. An advocate of occupational safety regulation, he has written and lectured extensively on occupational and respiratory protection issues.