Respiratory Health for Our Future
Sponsored by OHD, LLLP
OSHA’s standard for respiratory protection always ranks high on lists of the agency’s ten most frequently cited standards. For fiscal year 2017, respiratory protection ranks fourth. Why and how should respiratory protection issues be addressed? Let’s take a quick dive into a few of these violations.
Below are five common violations of OSHA’s respiratory protection standard, along with the number of citations for each that I’ve seen in my work as a respiratory protection specialist.
1. Medical evaluations, 1910.134(e)(1), 605 citations. Is a medical evaluation being given to determine if an employee is able to wear a respirator before he or she is fit-tested and required to use it in the workplace? Many times, a medical evaluation is performed, but does it take place first? The sequence makes a difference.
2. A written respiratory protection program, 1910.134(c)(1), 494 citations. Is a written program in place? Remember, if respirators are necessary in the workplace and required by the employer, the employer is required to establish and implement a program with work site-specific procedures and keep it updated with current regulations and changes.
3. Fit-testing, 1910.134(f)(2), 277 citations. Is fit-testing being performed? There are many specifics to fit-testing. If the respirator has a tight-fitting facepiece, the employer must ensure that it is fit-tested prior to initial use, whenever a different respirator facepiece (size, style, model, or make) is issued or used, and at least annually thereafter.
4. Voluntary use of respirator, 1910.134(c)(2)(i), 239 citations. An employer may provide respirators at the request of an employee or permit employees to use their own respirators if the employer determines that such respirator use will not create a hazard. Remember that if a respirator is needed, the employer must provide it.
5. NIOSH-certified respirator, 1910.134(d)(1)(ii), 224 citations. Is the respirator NIOSH certified? The National Personal Protective Technology Laboratory (NPPTL) through CDC has a certified equipment list available for search.
These issues are likely to arise again in 2018, but they are preventable. Of the nine steps of a respiratory protection program, the last step is to perform an annual assessment to find any issues and come up with a plan to fix them. Having a detailed, clearly defined respiratory protection program will significantly help minimize these citations.