Monday, January 5, 2015

Respiratory Protection Program - Annual Reviews

It’s often said that the devil is in the details, and that could not be truer than when it comes to the requirements of some of OSHA’s comprehensive health and safety standards. In fact, there are several OSHA standards that actually require affected employers to conduct annual program reviews, including the OSHA respiratory protection standard (see requirement at 1910.134(l)(1) and (2). Therefore, I am going to start off this New Year by outlining the problems most commonly identified when I assist employers with their annual respiratory protection program reviews.

Facial Hair – OSHA standard 1910.134(g)(1)(i)(A) states that employers “shall not permit respirators with tight-fitting face-pieces to be worn by employees who have facial hair that comes between the sealing surface of the face-piece and the face . . .”.  Unfortunately, this language is very subjective, and employers often . . .
  
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8 comments:

  1. 1910.134 does not require "annual" program evaluation. It requires evaluation as necessary to assure correct procedures & implementation. By practice, many employers do an annual review.

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    1. It is true the word "annual" does not appear in this standard. But the only way to "assure implementation" of the annual fit test requirement and the annual training requirement is to do an annual audit. So it will be required to audit your program at least annually.

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  2. Excellent Respiratory Protect Prog article … Thanks! Chuck

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  3. I always appreciate hearing about evaluations and the problems and deficiencies they encounter. It really helps when reviewing safety programs to see what needs to be improved. Thanks for sharing! Tony

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  4. Interesting article - Thanks for the info. I travel all over the U.S. doing power plant outages, refinery turnarounds, new construction, etc. On the facial hair - it is always a problem with a few craftsmen, not all. So when I run into a hard head who thinks he is fine with his 2 day beard, I always pull them back to safety office for a fit test. Do a positive/negative without the filters. Then filters on and use the smoke tube. It always works. They will see that the respirator is no longer tight fitting and not protecting their lungs...just a thought from out here in the field... Gene Taylor

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  5. When I visit a client, I check out the coat rack in the maintenance shop. If I see a respirator dangling from a hook, I know the client does not have an effective RPP. How long has it been there? Who was the last to wear it? Are the cartridges still good? Would you want to put that thing on your face and breathe the air? - Ron Klapperich, CSP, CHST

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    1. Ron. I know what you mean. Just last week I was conducting an audit, and I looked inside of the big yellow flammable storage cabinet where the maintenance department kept their paint stored. Sure enough, there were two 1/2 mask respirators with OV cartridges laying on one of the shelves. To make matters worse, the safety manager said he did not even know those type respirators were at the plant or that maintenance personnel were wearing them, which meant they were not included in the medical eval / fit test / training . . . programs at the plant.

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