OSHA Respiratory Protection Requirements

Employers should now be complying with all provisions of the Respiratory Protection Standard, 29 CFR 1910.134. We have highlighted a few of the key requirements below.

 

Respirator Fit Testing

Respirator fit testing is required prior to initial use, whenever a different facepiece is used, and at least annually thereafter. The standard states that all employees using tight-fitting full face positive pressure respirators (i.e. Self Contained Breathing Apparatuses [SCBAs], Supplied Air and Powered Air Purifying Respirators) must pass an appropriate respirator fit test.

 

Medical Evaluations

Employers must provide a medical evaluation to determine the employee's ability to use a respirator before fit testing and use. Employers must obtain a written recommendation regarding the employee's ability to use the respirator from a physician or other licensed healthcare professional (PLHCP).

Annual review of medical status is not required.

However, under certain circumstances employers must provide an additional medical evaluation:

  • The employee reports medical signs or symptoms related to the ability to use respirator;
  • The licensed healthcare provider recommends a reevaluation;
  • Information from the respirator program, including observations made during fit testing and program evaluation, indicates a need for additional evaluation;
  • Change occurs in workplace conditions that may substantially increase the physiological burden on an employee; or
  • A substance-specific standard (i.e. Asbestos & Lead) calls for additional testing and annual reevaluations.

 

Respirator Training

Required annually and when:

  • Workplace conditions change;
  • New types of respirators are used; or
  • Inadequacies in the employee's knowledge or use indicates need.

 

Recordkeeping

Records of medical evaluations must be retained and made available per 29 CFR 1910.1020. A record of fit test results must be established and retained until the next fit test.

 

Change-Out Schedules

In the past, OSHA stated that chemical cartridges and canisters needed to be replaced immediately when the respirator wearer detected warning properties (smell or taste) passing through the filters. This is no longer the case, as OSHA has made a change to this rule. OSHA now states respirator wearers must change out chemical cartridges and canisters before breakthrough is experienced.

According to OSHA, an air-purifying respirator may be used for protection against gases and vapors in atmospheres not immediately dangerous to life or health (IDLH), provided that "the respirator is equipped with an end-of-service life indicator (ESLI) certified by NIOSH for the contaminant OR if there is no ESLI appropriate for conditions in the employer's workplace, the employer implements a change schedule for canisters and cartridges that is based on objective information or data that will ensure that canisters and cartridges are changed before the end of their service life."

 

When an effective change-out schedule is implemented, air-purifying gas and vapor respirators may be used for hazardous chemicals, including those with few or no warning properties.

 

For further information on standards, interpretations, directives, technical advisors, and compliance assistance, please visit http://www.osha.gov/.