Is Your Respirator Program Effectively Managed?

March 1, 1999
Lincoln Electric employees are some of the most skilled, highest-paid factory workers in the country. Protective clothing keeps these valuable assets safe and on the job.

Life first stirred at the Department of Energy's Hanford Site in Richland, Wash., in 1943. The mission of the site was to produce plutonium for the world's first atomic weapons. It was known worldwide as the birthplace of the "Fat Man" bomb which was dropped on Nagasaki.

Now it is known as one of the most contaminated places on earth. The current mission at Hanford is waste remediation and environmental restoration.

Hanford has, admitted Cliff Ledford of Fluor Daniel Hanford, a number of serious safety hazards. Ledford is the administrator of a program which protects 6,000 workers against exposure to radiation contamination; chemicals such as barium chloride, potassium chloride, acetone, halogen hydrocarbons, boric acid, nickel sulfate, carbon tetrachloride and trichloroethylene; heavy metals, including thorium, lead, cadmium, bismuth, aluminum and barium; and hazardous materials such as asbestos. The respiratory protection program reflects the serious nature of the work.

In workplaces such as Hanford, respiratory protection can be a matter of life and death. An estimated 5 million workers in more than 1 million workplaces are affected by OSHA's respiratory protection standard, which took effect Oct. 5, 1998. Respiratory protection experts and administrators of respiratory protection programs such as Ledford agree that 29 CFR 1910.134 provides them with the practical guidance needed to maintain an effective respiratory protection program.

The standard requires that employers use engineering controls to protect workers and, if they are required, supply respirators to employees. Employers must designate a program administrator. Employers must have and follow a written program which contains procedures for selecting respirators; medical evaluations for respirator wearers; fit testing; cleaning, storing, inspecting and maintaining respirators; ensuring adequate air quality, quantity and flow of breathing air for atmosphere-supplying respirators; employee training and program evaluation.

"I think it's a good standard. It is well-written and basically clears up a lot of the confusion. It unifies the respiratory protection requirements found in other [substance-specific] standards by referring back to the respiratory protection standard," said David Abrams, CIH, president of ARS Environmental Health Inc., Minnetonka, Minn.

The new standard, said Abrams, a member of the respiratory protection committee of the American Industrial Hygiene Association, "codifies good practice."

And good practice is what Ledford promotes in the workplace. Respiratory protection was given a renewed emphasis at Hanford about five years ago, long before the new standard was implemented. "We think of OSHA standards as the minimum, a starting point," said Ledford.

Every process at Hanford is reviewed in an effort to eliminate or reduce contaminants so that respiratory protection will not be required. When it is necessary, the program starts with what Ledford refers to as "positive control" of respirator use in the workplace.

Issuance, use and return of respirators are closely monitored and carefully documented. Workers must show proof they have received a medical examination, proper fit testing and appropriate training before they are issued a respirator.

"It's all about employee safety," said Ledford. "I want them to have the very best respiratory protection program they can have out there in those atmospheres." The best program begins before employees set foot on the job, he added.

Medical Exams and Fit Testing

Before being issued respirators, Hanford employees are given medical examinations which take job tasks and work conditions into consideration. If employees pass the medical exam, they are allowed to proceed to fit testing.

Hanford employees receive annual fit tests. The OSHA standard requires either a qualitative test or a quantitative test; DOE facilities offer both. A qualitative test, used when contaminants in the air are no more than 10 times the permissible exposure limit (PEL), relies on the employee's response to a test agent. A quantitative test assesses a respirator"s fit by measuring the amount of leakage of a test agent into the respirator and verifies a protection factor of greater than 10 times the PEL. Fit tests are also required when the type or model of respirator changes or if a worker experiences physical changes, such as weight loss or gain.

Respirator manufacturers said they have received a number of questions about the standard's fit testing requirements, which are considered to be the most expensive portion of the standard to implement.

"Fit testing has been ambiguous for years," said Bruce Schorer, marketing manager for air purifying and industrial, Scott Health and Safety, Monroe, N.C. "Employers would hand employees a respirator and ask them if the seal on the respirator felt tight. Now employers must follow fit testing protocols in the standard and must offer employees a selection of respirators."

He said Scott is responding to the fit testing portion of the standard by offering a range of face pieces which can work with a number of respirators, so that if an employee needs to change the type of respirator he or she uses, the fitted face piece can be attached to the new respirator without a new fit test.

At Hanford, employees must show documentation they have been properly fit tested, including the type and model of respirator for which they were fit tested, before they are allowed to proceed to training. Once training is completed, employees must show all three cards from the medical examination, fit testing and training each time they request a respirator. "If they don't have all three," said Ledford, "they don't get a respirator and they can't work."

Site-Specific Training

One of the key provisions of the respiratory protection standard is that training be site-specific. Experts warn that facilities which rely exclusively on corporate or "canned" programs supplied by a professional training company might not be in compliance with the standard. "No matter how good it is, every program needs a little bit of tweaking to make it site-specific," said Abrams. "The new standard has affected everybody in that aspect."

Hanford has a state-of-the-art training facility, called the Volpentest HAMMER Training and Education Center, which provides lifelike, hands-on training for a number of emergency and work-related situations. The facility includes a six-story training tower, a burn structure, storage tanks, a waste tank prop, a trench prop, a confined space dive pool and a prop of a remediation site. "We can train employees for any situation they might encounter," said Ledford.

Not only is training site-specific at Hanford, but the trainers know the jobs first-hand.

"All our trainers are bargaining unit people, so we have workers training workers," said Ledford, adding that the arrangement has gotten "a 99 percent positive response from employees."

Classes, which occur on a daily basis for 10 to 15 workers, are kept at a ratio of four employees to one trainer. After four hours of classroom discussion about respiratory hazards, use and maintenance of respirators and site-specific concerns, the trainees are taken to the HAMMER facility, where they practice donning and doffing their respirators. When they are confident in their abilities, they are tested using a 20-item checklist. If they miss one of the critical elements on the checklist, they have to review the procedure before being retested. Hanford, in accordance with the new standard, offers refresher training when necessary and additional training if new equipment or working conditions are introduced.

"Employees feel comfortable talking to other employees. They listen to the trainers because they are hourly workers, too. The trainers understand what it's like to work in 120 degrees in the summer and minus 10 degrees in the winter. They understand the different conditions employees face. It adds credibility to our program," Ledford said.

Employee Feedback is Key

Experts agree that employee feedback is a crucial part of evaluation for any respiratory protection program.

Ed Kahal, CIH, is respiratory protection program administrator for more than 4,000 respirator wearers at Westinghouse Savannah River Co. in Aiken, S.C., another DOE complex. He uses sampling data from the jobs involving respiratory protection, observations by occupational safety and health professions, walk throughs, an annual formal audit and quality assurance audits and regular building audits (which include respiratory protection) to evaluate his program. But some of the most useful information he receives, he admits, comes from spending time out in the plant and attending roundtable meetings with employees. He also receives regular calls and e-mails with questions about the program or concerns about specific respiratory protection equipment. He said he has learned a lot from these discussions.

"Employees tell me about unusual events. For example, an employee dons a respirator and feels like his breathing is restricted. He is told to leave the work area and change out the respirator for a new one. Maybe a suit doesn't seem to inflate properly or an airline respirator is difficult to connect. It's a way for me to track employee knowledge about the equipment, determine the effectiveness of the program and judge the maintenance program," said Kahal.

Ledford said he thinks it's important to talk to workers on all shifts, since atmospheric conditions, temperature or the amount of work may vary, depending on the time of day. "I talk to employees on swing shifts, graveyard shifts. You"d be surprised at the information I"ve gotten at 3 a.m. I"m not always aware of the work conditions during certain shifts, and employees might not remember to tell me when they"ve finished their shift. But if I'm there while they're working, they remember to mention their concerns and questions. My wife doesn"t like it much, but it sure helps me out," he said.

According to Felicia J. Phillips, MS, CIH, such informal discussions can be a non-threatening way to talk about employee comfort. Phillips, who works for DESE Research Inc., Huntsville, Ala., and teaches respiratory protection courses at the Deep South Center for Occupational Health and Safety, said that employee comfort should be a major consideration in the selection and use of respiratory protection, so it is important to offer them several makes and models of respirators whenever possible. Discussions with employees "build confidence in the program and further exemplify an employer's commitment to a safe and healthy workplace," said Phillips.

Program administrators who get out in the field and talk to employees are making the right move, said Larry Janssen, Regulatory Affairs and Training Group, 3M, St. Paul, Minn.

"OSHA is looking for performance. Watch employees. Do they know how to wear their respiratory protection? Do they know when to wear it? The best written program in the world is not effective if not followed," said Janssen, a former OSHA compliance officer. "Talk to employees and listen to what they say. That is probably the best way to evaluate the effectiveness of your program."

APFs are MIA

While training, maintenance and employee participation are important elements of respiratory protection, a program which does not offer the correct level of protection will not be effective. Which brings us to what many program administrators and experts admit is the most confusing part of the standard: the lack of a cartridge change-out schedule or assigned protection factors (APFs), which define how much protection a respirator offers against contaminants. According to OSHA, APFs are in the works and will be available later this year.

Until OSHA releases its own APFs, both the National Institute for Occupational Safety and Health (NIOSH) and the American National Standards Institute (ANSI) offer APFs. The respiratory protection standard refers users to the NIOSH APFs, although employers can use either ANSI or NIOSH APFs.

"OSHA wanted to put pressure on end users, so the standard requires users to take responsibility when respiratory protection is required. They need to know the contaminants in the workplace; know their concentrations; know the work rate of the employee; and know atmospheric conditions, such as the presence of high temperatures," said Leslie Abbot, APR product manager, Survivair, Santa Ana, Calif.

Manufacturers offer change-out schedules for their cartridges, she said, and suggested that end users call distributors or manufacturers if they have questions. She cautioned end users to be aware that the new standard requires them to determine when to change out the cartridge before breakthrough occurs.

What that means, she explained, is that if "a cartridge's breakthrough time is four hours, then you should change it out before it expires, at three hours and 45 minutes, for example." When to change out cartridges can be a cost issue for many companies, she added. A company with 100 employees wearing respirators eight hours a day loses 50 hours' worth of cartridge time daily by changing each four-hour cartridge out 15 minutes early.

Waiting to change out cartridges until a taste or smell indicates breakthrough is a quick way to an OSHA citation, warned Felicia Phillips. "OSHA has wisely recognized the wide range of variability in individual odor thresholds. It is unacceptable to rely on contaminate breakthrough as a cartridge replacement indicator," she declared.

Although Kahal refers to respirator manufacturers' Websites and to presentations offered by his main suppliers, he examines change-out schedules "on a case-by-case basis, looking at working conditions, contaminant levels and the permissible exposure limits. I try to avoid a hard-and-fast rule about changing cartridges." Kahal follows the ANSI APF table that is mandated by DOE orders.

Despite their disappointment that OSHA did not include APFs in the standard, program administrators and respiratory protection experts agree that companies which follow the OSHA standard won't go far wrong.

By following the standard, said Ledford, employers ensure that employees wearing respirators are protected to the highest degree possible against the specific contaminants they encounter in the workplace. It ensures employees are medically qualified, mask-fitted, and trained to the specific respirator they will wear.

But, said Ledford, never lose sight of the most important aspect of a respiratory protection program or the goal of the OSHA respirator standard: "It ensures the wearer will safely go home to his family at the end of the work day."

Expert Advice

"Network with other respirator program administrators at your company. You can save time and, sometimes, money. Fernald had 3,000 respirators they were going to throw out as excess. We got them for the cost of shipping, $746. For us to buy those respirators, which we needed anyway, would have cost $2 million." Cliff Ledford, respiratory protection program administrator, Fluor Daniel Hanford.

"When you order respirators, make sure the people in your purchasing department understand what respirators are needed and why. Otherwise, they may make substitutions based on cost factors, which is not a good way to choose a respirator." David Abrams, president, ARS Environmental Health Inc., Minnetonka, Minn.

"With the weapons of mass destruction scenarios being suggested, there is a need for personal protective clothing and respirators which offer protection from a variety of nuclear, biological and chemical hazards. New products are coming into the market. Be aware of the new products which are available." Bruce Schorer, marketing manager for Air Purifying and Industrial, Scott Aviation.

"Looking back on my years at OSHA, one of the most common problems we saw was with the maintenance of respirators. Are workers cleaning, storing, repairing and inspecting respirators properly? It's a part of the program no one wants to deal with, but it's crucial." Larry Janssen, Regulatory Affairs and Training Group, 3M, St. Paul, Minn.

Big companies must not lose sight of their smaller subcontractors, who might not fulfill parts of the standard, such as medical evaluations or proper fit testing. Make sure your subcontractors have written programs and are in compliance with the OSHA standard; address the issue in contracts." Ed Kahal, respiratory protection program administrator, Westinghouse Savannah River Co., Aiken, S.C.

"It is essential that a program administrator be very familiar with the respiratory hazards in the workplace and the types of respiratory protection that are available. One of the driving forces in revising the respirator standard was to reflect technological advances in the field of respirator protection... The administrator's level of knowledge should be commensurate with the technology in the workplace." Felicia J. Phillips,DESE Research Inc., Hunstville, Ala.

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