Appendix O—Respiratory Protection Program

A. Introduction
The overall objective of this program is to outline the procedures that must be followed if an EMU Science Center employee or student is required to wear a respirator for protection from air borne gases, liquids, vapors or fumes at levels at or above OSHA permissible exposure limits, or if an individual chooses to wear a respirator for protection below the permissible levels. The components of this program address:
1. The respirator selection and issuing process for the particular hazard situation—routine or regular exposures, infrequent predictable occasions or emergencies where there is a leak or spill.
2. When and how respirators will be used in routine work activities and cleanup of minor spills.
3. How respirator fit-testing is done.
4. How employees are trained about the respiratory hazards in the work place.
5. Training procedures for proper use of assigned respirators.
6. Respirator storage, cleaning, maintenance and repair.
7. Medical evaluations of respirator users.
8. Evaluation of the effectiveness of the respirator program and record keeping.
B. Responsibilities
1. Responsibility for the Science Center Respirator Program resides with the Chemical Hygiene Officer. It includes overseeing the development of this program and ensuring that it is carried out in the workplace. The CHO will also evaluate the program regularly to make sure adequate protection is provided.
2. EMU Health Services is responsible for administering the medical surveillance program and maintaining medical records required by the program.
3. The Lab Coordinator and Anatomy Lab Instructor(s) ensure that the program is understood and followed by the workers under their charge, including:
a. Ensuring that employees under their supervision (including new hires) have received appropriate training, fit testing, and annual medical evaluation.
b. Ensuring the availability of appropriate respirators and accessories.
c. Being aware of tasks requiring the use of respiratory protection.
d. Enforcing the proper use of respiratory protection when necessary.
e. Ensuring that respirators are properly cleaned, maintained, inspected, and stored according to the respiratory protection plan.
f. Ensuring that respirators fit well and do not cause discomfort.
g. Continually monitoring work areas and operations to identify respiratory hazards.
h. Coordinating with the Chemical Hygiene Officer on how to address respiratory hazards or other concerns regarding the program.
4. Each employee and student in the respirator program has the following responsibilities:
a. To wear his or her respirator when and where required and in the manner in which they were trained.
b. Care for and maintain their respirators as instructed, and store them in a clean, sanitary location.
c. Inform their supervisor if the respirator no longer fits well, and request a new one that fits properly.
d. Inform their supervisor or the program administrator of any respiratory hazards that they feel are not adequately addressed in the workplace and of any other concerns that they have regarding the program.
C. Selection of respirator

D. Respirator fit testing
1. All employees who wear tight-fitting respirators will be fit tested before using their respirators or given a new one. Fit testing will be done annually. Fit testing will also be done when there is a physical change in an employee's face that would affect fit, such as wearing a beard or when the employee or medical provider notify the program administrator that the fit is unacceptable. The annual fit test protocol uses the isoamyl acetate option and follows the OSHA Fit Testing Procedures 1910.134, Appendix A.
2. Each time after donning the respirator a user seal check is to be done by alternately obstructing the inhalation and exhalation valves with the palm of the hand. A good seal will allow some pressure build-up before break through. Adjusting the head and neck strap can be used to improve weak seals.
E. Chemical Hazard Training
1. All employees and students who have a potential for an exposure to a hazardous chemical above the 8hr TWA, OSHA permissible exposure level, are informed of its hazard(s) primarily by reviewing the manufacturer's SDS prior to working with the chemical. The training includes measures that can be taken by the employee or student to minimize exposures. Steps applicable to the mentioned formaldehyde exposure include gloves, protective clothing and ventilation (engineering controls). See Appendix P, Formaldehyde Standard Operating Procedure.
F. Respirator storage, cleaning, maintenance and repair
1. After each use the internal surfaces (facial contact areas) are to be sanitized with 70% alcohol wipes. After each 4 uses, remove the cartridges and the circular flat inhalation valves. Immerse the face piece and straps into a warm water bleach solution (1 mL bleach in 1 L of water) plus one-half teaspoon of commercial soap. Carefully wash the circular inhalation valves in the cleaning water, rinse and spread on a flat surface to dry, or dry with paper towels. Re-attach the flat circular valves.
2. Respirators are to be inspected before and after each use and during cleaning. Damaged, deteriorating or improperly functioning components are to be removed and replaced as needed. Repairs are to be made employing only manufacturer's parts.
3. Determining the useful life of a cartridge is difficult given their infrequent use. An indication of a saturated absorbent is a noticeable odor of formaldehyde—definitely a sign for a replacement. Given that moisture also contributes to saturation, cartridges should be changed out annually to avoid experiencing break-through.
G. Medical evaluation of respirator users
1. Employees who voluntarily use respirators must be physically able to perform the work while using the respirator. Accordingly the employer has the responsibility of ensuring that the employees are medically fit and able to tolerate the physical and psychological stress imposed by introducing respirator use. Such determinations must be made by a licensed health care professional (LCHP) using the guidelines in Appendix C to 1910.134: OSHA Respirator Medical Evaluation Questionnaire, Appendix O(2). Copies are available in EMU Health Services.
2. The LCHP must be given the following information: Type of respirator to be worn, duration and frequency of respirator use, expected physical work effort, use of other protective clothing and equipment to be worn, and temperature and humidity extremes that may be encountered.
3. Respirators are not to be worn until a medical evaluation is performed and approval granted. The employee is to receive a written recommendation from the LHCP on whether or not the employee is medically able to wear a respirator. (Appendix O(3)) It must identify any limitations of use as well as specifying whether or not periodic or future medical evaluations are required by the LHCP. Copies of the written recommendations should be provided to the Chemical Hygiene Officer.
H. Evaluation of effectiveness of respirators and recordkeeping
1. The Chemical Hygiene Officer will perform an annual evaluation of the respirator program involving feedback from employee participants and the LHCP. The CHO will establish and maintain electronic records of medical evaluations, fit testing, appropriate respirator selection and annually review and update this program as necessary.
Revised by LMY January 2018