1. Policy Statement
a) In our ongoing pursuit of a safe and healthful work place, ESCO Group has developed a Respiratory Protection Program to be followed by all employees required to wear respiratory protection to enhance the safety of their work environment.
2. Administrative Responsibility
a) The ultimate responsibility for the administration of this program shall lie with the Safety Director and acting Respiratory Program Administrator. The day-to-day aspects of the program are the responsibility of the site supervisor and the employee to whom respiratory protection is assigned. ESCO Group has authorized the Respiratory Program Administrator to recommend halting any operation of the company where there is danger of serious personal injury. This policy includes respiratory hazards.
3. Selection of Respiratory Protection
a) The following criteria are used in the final selection of a suitable respirator:
i. Identification of Hazard(s)
1. Respirators will be selected on the basis of hazard(s) to which the worker is exposed. The Safety Department will be responsible for surveying the work environment to class hazard(s) into the following definitions/classes:
a. Gas/vapor contaminants
b. Particulate/dust contaminants
c. Fume contaminants
d. Mist contaminants
e. Oxygen deficient atmospheres
f. Atmospheres immediately dangerous to life and health
g. Combination of classes
ii. Evaluation of the Hazard(s)
1. Trained and competent personal will take air samples in the work environment to determine the actual concentration of exposure hazards, which may be present. All methods used in hazard evaluation are in compliance with OSHA/NIOSH sampling methodologies. Air samples requiring laboratory analysis will be submitted to an AIHA accredited laboratory.
2. The resulting concentration is to be compared with current OSHA (PEL) or ACGIH (TLVs), which is lower, to assist in determining the level of protection required.
iii. Appropriate Selection and Purchasing
1. This step is completed by the Safety Director and Safety Committee aided by information provided by outside experts specifically trained in occupational health and industrial hygiene, where required.
2. Selection shall consider facial irregularities (e.g., scars, dentures, facial hair) and the workload of the employee in comparison with any possible resistance/stress placed upon the employee’s respiratory system by the protective device.
3. Only appropriately sized respirators shall be assigned to individuals.
4. Only NIOSH/OSHA approved respirators will be provided by the ESCO Group. Respirators and respirator equipment will be provided to all affected employees at no cost.
iv. Procedures for Immediately Dangerous to Life or Health (IDLH) Atmospheres
1. The ESCO Safety Director must authorize any work in IDLH atmosphere.
2. An ESCO employee will be stationed outside of the IDLH atmosphere. Communication will be maintained with employees working inside the IDLH atmosphere at all times, this may include visual, voice or signaling.
3. A job briefing will be completed by the ESCO supervisor for all employees involved prior to entry into an IDLH atmosphere. The job briefing will be documented with the Job Hazard Analysis form and will include emergency procedures and the necessary steps to complete the job in the IDLH atmosphere successfully.
v. Breathing Air
1. Compressed breathing air will met the requirement of Grade D breathing air described in ANSI/Compressed Gas Association Commodity Specification for Air, G7.1-1989. A certificate of analysis from the supplier will be maintained documenting cylinders contain Grade D breathing air.
2. Breathing air couplings must be incompatible with outlets for non-respirable air and other plant gas systems.
vi. Voluntary use of Respirators
1. 29 CFR 1910.134, Appendix D will be provided to employees who wish to wear particulate respirators (dust masks) but are not requried based on hazard analysis. Voluntary use of respirators will be documented on the “EMPLOYEE VOLUNTARY RESPIRATORY ACKNOWLEDGEMENT” form. P. AA 34
vii. Respirator Changeout
1. An employee must leave the hazardous atmosphere to change out respirator cartridges due to breathing resistance or if the employee detects break through, they must leave the space immediately.
2. To clean the respirator due to fogging or other reasons, the employee shall leave the space before breaking the seal on the respirator.
4. Medical Evaluations
a) To insure the examining physician can render a qualified opinion regarding the employee’s use of respiratory protection, they shall be provided the following information by the Safety Director.
i. Type of respirator to be used.
ii. Task that will be performed.
iii. Length of wear.
iv. The toxic substances involved, and
v. Verbal communications required in the task.
b) Medical examination and testing – Medical examination and testing shall take place prior to an employee using respiratory protection.
i. A medical/occupational history questionnaire, (Appendix C) shall be completed by the employee prior to meeting with the physician. The medical evaluation prior to fit-testing shall be kept confidential and the employee shall be given a chance to discuss the results with the physician or other licensed healthcare professional.
ii. The following tests will be completed:
1. Pulmonary function tests including FVC and FEV (if indicated)
2. The physician will be responsible for requesting any other test (e.g., chest X-ray, EKG) he or she fells necessary to render a qualified opinion.
c) Re-examinations – All employees required or assigned respiratory protection shall be re-examined on an annual basis.
5. Assignment of Respiratory Protection
a) Whenever possible, a respiratory protective device shall be assigned to an individual for his or her exclusive use.
i. Identification – All respiratory protective devices will have a permanent, durable identification marking(s) attached to it that does not interfere with the performance of the device.
ii. Permanent assignment – When a respirator is assigned to an employee for his or her exclusive use, records will be kept indication the employee and the specific respirator assigned. The Safety Director will maintain these records.
iii. THE ESCO GROUP Safety Director shall do temporary emergency respirator assignment.
1. When a respirator is temporarily assigned to an employee, records shall be kept. These records will include the employees I.D., respirator I.D., description of operation of hazard area, and length of assignment. The Safety Director will maintain these records.
2. During emergency respirator use, efforts shall be made to collect the above information.
3. Employees’ assigned respiratory protection on an emergency basis will be required to perform an inspection and fit testing prior to donning in conformance with Sections VI and VIII of this policy.
6. Training and Education
a) Prior to assignment of a respiratory protection device, those employees being considered shall receive training which includes the following:
i. Explanation of the ESCO Group’s respirator policy.
ii. The responsibility of the program administrator.
iii. The employee’s responsibility.
iv. Explanation of the respiratory hazards posed by the operations and regulated areas.
v. Explanation of current administrative and engineering controls used in conjunction with respiratory protection.
vi. Explanation of selection process.
vii. The functions, capabilities, and limitations of the selected respirator.
viii. Demonstrations on the donning fit testing, and proper wearing of the respirator.
ix. Respiratory maintenance, cleaning, and storage.
x. The federal and state government’s regulatory requirements.
xi. Emergency situations.
b) As part of the training, the employee will have the opportunity to handle the selected respirator, have it fitted properly, test the face piece to face seal, and wear it in “normal” air. The Safety Director will be responsible for the training of all employees who use a respirator.
i. Training will also be required whenever the following conditions exist:
1. Close-call event
2. Program related injury
3. Change in job assignment
4. New hazards or equipment
5. New hazard control methods
6. Failure in the safety procedures
7. Reason to doubt employee proficiency
7. Fit Testing
a) All employees who are issued respirators will be fit tested prior to use for each respirator make, model, style or size. The program administrator will choose the most appropriate mean(s) of fit testing for each employee and type of respiratory protection assigned. Employees will be re-fit tested on the following basis
i. Any visual observations of physical changes which may affect the fit of the respirator such as dentures, surgery or significant weight loss.
ii. Employee notifies program administrator that the fit of the respirator is unacceptable.
b) There are two types of fit tests: Qualitative and Quantitative tests. Qualitative tests are fast, usually simple, but not as accurate an indicator of improper fit as the quantitative test. The quantitative test, although more accurate, requires the purchase of expensive equipment, requires a specially trained operator, and in many instances is of limited use due to its complexity and bulk.
c) Two other qualitative fit test, the positive pressure fit test and the negative pressure fit test, will be used as a quick check of the fit of the respirator face piece each time employees put the respirators on.
d) Test Atmosphere
i. Regulators require that the user be allowed to test the face piece-to-face seal of the respirator and wear it in a test atmosphere. The test atmosphere amounts to an enclosure in which 1) the user can enter with the equipment on, and 2) a “test” contaminant (of low toxicity) can be placed.
e) Test Methods
i. As mentioned above, there are Qualitative and Quantitative tests. The use of both types of tests depends on, among other considerations, the severity and extent of the respiratory hazard. During any fitting test, the respirator head straps must be as comfortable as possible. Tightening the straps will sometimes reduce face piece leakage, but the wearer may be unable to tolerate the respirator of any length of time.
f) Qualitative Tests
i. Qualitative tests are fast, require no complicated expensive equipment, and are easily performed. However, these tests rely on the wearer’s subjective response, so are not entirely reliable. There are two major qualitative tests:
ii. Isoamyl Acetate Test
1. Isoamyl acetate, a low toxicity substance with a banana-like odor, is used widely in testing the face piece fit of organic vapor cartridge/canister respirators. The substance is applied to the cotton wad inside the enclosure. The prospective user should put on the respiratory protection equipment in an area away from the test enclosure so that there is no prior contamination of the cartridge on “pre-exposure” to the isoamyl acetate.
iii. Irritant Smoke Test
1. The irritant smoke similar to isoamyl acetate test in concept is used widely in testing the face piece fit of particular filter respirators. This test can be used for both air-purifying and atmosphere-supplying respirators, but both air-purifying and atmosphere-supplying respirators must have a high efficiency filter(s). The test substance is an irritant (stannic chloride or titanium tetrachloride), which is available commercially in sealed glass tubes. When the tube ends are broken and air passed through them (usually a squeeze bulb), a dense irritating smoke is emitted. In this test, the user steps into the test enclosure and the irritant are “sprayed” into the test hole. If the user detects any of the irritant smoke, it means a defective fit, and adjustments or replacement of the respirator are irritant smoke test must be performed with caution because the aerosol is highly irritating to the eyes, skin, and mucous membrane. As a test has a distinct advantage in that the wearer usually reacts involuntary to leakage by coughing or sneezing. The likelihood of giving a false indication of proper fit is reduced.
iv. Negative Pressure Test
1. This test (and the positive pressure) should be used only as a very gross determination of Fit. The wearer should use this test just before entering a hazardous atmosphere. In this Test, the user closes off the inlet of the canister, cartridge(s), or filter(s) by covering with the Palm(s) or squeezing the breathing tube so that it does not pass air, inhales gently so that the Face piece collapses slightly, and holds breath for about 10 seconds. If the face piece fills back up with air, the wearer may not enter the hazardous atmosphere. At this time the program administrator will choose a new respiratory and start the fit testing over.
8. Cleaning and Disinfecting
a) All respirators shall be cleaned and disinfected per the manufacturer requirements as follows:
i. Permanently assigned respirators – Those respirators assigned to an employee for his or her exclusive use shall be cleaned and disinfected as needed, but no less than weekly.
ii. Temporary or emergency assigned respirators – Those respirators assigned on an emergency or temporary basis shall be cleaned and disinfected after each use and prior to each reassignment to another employee.
9. Inspection and Repair
i. All respirators used under permanent or temporary assignment shall be inspected prior to donning by the assigned employee. The employee shall be responsible for inspection of the following points:
1. Straps, cartridges
2. Face seal
3. Exhaust and inlet valves
4. Air hose connections or blower
ii. If repairs are needed, these should be completed in accordance with paragraph B.
iii. Emergency assigned respirators shall be inspected at least monthly and will be documented by the Safety Director. All points required by the manufacturer and those in paragraph A1 will be included in the emergency respirator inspection process.
b) Repairs – The Safety Director will designate an individual that has been appropriately trained to properly repair or service the respirators used in the program. If respirators must be removed from service or cannot be rapidly repaired, an interim respirator shall be temporarily assigned.
a) All respirators shall be stored in a clean, contaminant-free environment. The respirator/face piece shall be placed in a plastic bag to ensure the contaminant does not get into or onto the face piece of the respirator. Whenever possible, respiratory protection should be stored in a secured area.
11. Program Evaluation
a) On an annual basis, the program administrator and appropriate department supervisors shall review all points of the program with the affected personal to ensure effectiveness and workability. Furthermore, all program points shall be reviewed in comparison to current state and federal regulations to ensure proper compliance.