Tackling OSHA’s Top 10 Citations: 1910.134 - Respiratory Protection
The following is an excerpt from Tackle OSHA’s Top 10.
Hosted by Chief Safety Officer Jill James, you can listen to the webcast on demand.
We have a picture here, of all the different ... many different types, rather, of respirators that employees could be using. The employer's responsibility is to be providing the right type of hazard, or right type of respirator, rather, for the hazard the employee is exposed to.
And if we back it up even further than that, when we know our employees could be exposed to a respiratory hazard, the first question on a safety person's mind should be, "Is there a way I could eliminate the need for a respirator at all?" So could we engineer the hazard out? Could we be using something that's less dangerous, that we wouldn't need a respirator for? Is there a way we could use local ventilation, rather than putting an employee in a respirator? So that should be our first line of defense, before we start thinking about personal protective equipment.
So a question that I get asked often is, "How do I know if it's really a respirator, and is that thing in the lower-right-hand side really a respirator, because it looks like a dust mask that we can go and buy at Home Depot?" The answer is yes, anytime we have a mask that has two straps behind the head, that is a respirator. The kind that your dentist might wear, that they hook around their ears, that's not considered a respirator, but if it has two straps, it's a respirator.
So what would I be looking for? What do employees need to know? As an auditor, I would be looking to see how the respirators are being stored. If they're simply hanging on a nail somewhere, in a work area, that respirator is getting dirty, and its filters are getting ... They're always being active, and we want to be able to have a clean respirator for our employees to wear, so you'd want it sealed in some kind of container, maybe a Ziploc bag, or some kind of closed container that it can stay clean.
Then, would the employees know the proper way to clean the respirator and take it apart? What would they clean it with, and are the detergents they're using something that could break down the components of that respirator? So when I would do my employee interviews during my standard OSHA inspections, I would ask employees that. I'd ask if they had training on how to clean the respirator, and then also, if the employer is providing what's called fit testing, to ensure that the right size of respirator has been chosen for that employee's face, so that it's fitting properly and tightly, so that there isn't an ability for whatever hazard you're trying to protect from infiltrating that employee's breathing space.
Then, not all employees, not all human beings, are suited to wear a respirator. Some of us might have medical conditions that prevent us from being able to safely wear a respirator. Maybe someone has asthma, or maybe they take a certain type of medication, that it creates a greater hazard for their health to be wearing a respirator. So all employers are required to have their employees be determined whether or not they're medically suited to wear a respirator.
That's done through the use of a questionnaire that's in the regulation for respirator use. There's an appendix to the federal law on respirators, and the employee would fill out that questionnaire, and then have that privately reviewed, the answers, and when I say private, it's asking private medical questions, so they would fill out the questionnaire, then hand it off to a physician, or someone who is qualified to review respirator questionnaires, to determine whether or not that employee is healthy enough to wear a respirator, or if they need further testing to determine if they can wear a respirator.
So, stage one is to review the medical questionnaire, and if they say, "Well, we're really not sure. They gave us an indication by answering in a certain way, that maybe they need a spirometry test, or maybe they need a lung function test, or maybe they need to have some other evaluations before we can safely say they can wear that respirator," and then that feedback would come back to you as the employer.
Again, with that, as a former regulator, I'd be asking whether or not the employer has a written program, explaining how respirators are being used in their workplace, how they're doing fit testing, what type of fit testing they're doing, how the medical evaluations are being addressed, how training is occurring, and how respirators are to be stored. Then, how did you do an evaluation, as an employer, to determine, "What kind of respirators do our employees need to wear for the hazards that they're exposed to?"
So is respiratory training required under the federal law? Yes it is, on both sides of the house, whether it's construction or general industry