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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