Respiratory Protection: Setting Up a Respiratory Protection Program - Step by Step
Setting up a respiratory protection program may seem a daunting task, but here is a simple step-by-step approach to help you get started. For specific regulatory requirements, refer to the Cal/OSHA respiratory protection standard found in Title 8, California Code of Regulations, Section 5144, Respiratory Protection.
STEP 1: Determine if you need a respiratory protection program
If you’re not sure if you need a respiratory protection program, refer to the State Fund fact sheet Respiratory Protection – Who Needs a Written Program.
If at all possible, you should eliminate the need for respirators by reducing employee exposure to hazardous materials. This can sometimes be done by using less toxic materials or implementing engineering controls such as ventilation.
STEP 2: Designate a program administrator
The program administrator is responsible for administering or overseeing the program. This individual must be qualified by training or experience to implement the program. The program administrator also conducts the required evaluations of program effectiveness.
STEP 3: Select the proper respirator
The OSHA Respiratory Protection eTool can assist you in identifying the type of respirator that should provide adequate respiratory protection. Note that some specific Cal/OSHA regulations will specify the type of respirator that must be worn. Examples include the regulations for asbestos and hazardous waste operations and emergency response.
If respirators with chemical cartridges or canisters are used for protection against gases or vapors, you will need to develop a change schedule. The NIOSH Respiratory Protection eTool provides guidance on developing a change schedule for organic vapor cartridges. Many respirator manufacturers have similar software available online for their products.
STEP 4: Provide medical evaluations for employees
Respirator use may place a physiological burden on employees. Therefore, medical evaluations are needed to determine if the employee is able to use a respirator. These evaluations are required before the employee is fit tested or required to wear a respirator.
The medical evaluation is conducted by a physician or other licensed health care professional (PLHCP) using a confidential medical questionnaire or an initial medical examination that obtains the same information as the questionnaire. This questionnaire is found in Appendix C of the Cal/OSHA respiratory protection regulation. Depending upon the results of the initial evaluation, a follow-up medical examination may be needed before a final determination is made regarding the employee’s ability to use a respirator.
STEP 5: Conduct fit testing
Respirators that have a tight-fitting facepiece are not one-size-fits-all. These facepieces must form a proper seal around the wearer’s face in order to prevent contaminated air from leaking into the facepiece. Therefore, fit testing is required before initial use and at least annually for all employees who are required to wear a respirator with a tight-fitting facepiece. This applies to both air-purifying and atmosphere-supplying respirators regardless of whether they are operating in a positive or negative pressure mode.
There are two general methods of fit testing, qualitative and quantitative. In some cases, quantitative fit testing is required. In others, either method is allowed. No matter what type of fit testing method you use, there are OSHA prescribed fit testing procedures that must be followed. These protocols can be found in Appendix A of the Cal/OSHA respiratory protection regulation.
STEP 6: Develop a written respiratory protection program
All the elements of your respirator program must be incorporated into a written respiratory protection program that is work-site specific. When exactly should you develop your written program? It might not be your first step, but it’s a good idea to complete your written program before you train your employees. That way, you will have a clear set of policies and procedures in place when you conduct your training. To assist you with this task, State Fund has developed a template that can be easily modified to suit most workplaces.
STEP 7: Provide training
Respirator training must be provided to all employees who are required to wear respirators. This training needs to be comprehensive, covering all aspects of respirator use, including such topics as the purpose, capabilities, limitations, inspection, and care of the respirator.
Videos and safety publications can provide general information on the use of respirators. You also need to provide more specific information on the particular respirators used by your employees and the policies and procedures in place at your workplace.
STEP 8: Inspection, care, and maintenance
Your workers are wearing their respirators, but are they really protected? A missing or damaged valve, a respirator cartridge that has never been changed, and poor quality breathing air are just a few problems that could arise without proper inspection, care, and maintenance.
Respirators used in routine situations must be inspected before each use and during cleaning. Emergency respirators must be inspected at least monthly and checked for proper function before and after use. Respirators that fail an inspection must be removed from service. For specific information on the inspection, maintenance, and care of the respirators in your facility, refer to the manufacturer’s instructions.
STEP 9: Evaluate the program
To ensure that your respiratory protection program is effective, you must have procedures in place for regularly evaluating it. You will need to determine if the elements of the written program are being implemented and if the written program is effective. Input from the employees wearing the respirators can help identify problems and determine program effectiveness. All aspects of the program should be evaluated, from respirator selection to maintenance and care.
STEP 10: Keep records
Records of medical evaluations, fit testing, and training must be kept. If air monitoring was conducted as part of your workplace hazard assessment, those records must be maintained also.
Additional Resources
The Cal/OSHA regulations for respiratory protection: www.dir.ca.gov/Title8/5144.html
All Cal/OSHA regulations: www.dir.ca.gov/samples/search/query.htm
Respiratory Protection eTool: www.osha.gov/SLTC/etools/respiratory/index.html
Policyholders that would like assistance with their respiratory protection program can request an industrial hygiene consultation through State Fund’s Loss Control Department or their broker.
The above evaluations and/or recommendations are for general guidance only and should not be relied
upon for legal compliance purposes. They are based solely on the information provided to us and relate
only to those conditions specifically discussed. We do not make any warranty, expressed or implied, that your workplace is safe or healthful or that it complies with all laws, regulations or standards.
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