OSHA compliance

Responding is Andy Morgan, national respiratory sales manager, Honeywell, Kansas City, MO.

We’ve recently turned the calendar to a new year, so now is a good time to reevaluate your respiratory program to ensure you’re OSHA compliant. OSHA’s standard on respiratory protection (1910.134) is one of the agency’s most frequently cited each fiscal year.

So, what do we need to know?

First, let’s start with what OSHA says regarding when and why we may need to wear respiratory protection: “Whenever there is a respiratory hazard, or potential for a respiratory hazard at a worksite, all employers are required to establish a written respiratory protection [program].”

A respiratory hazard can be identified in several ways. Most often, it’s through air monitoring in the potentially hazardous area to identify the contaminant present and its concentration. Hazard identifications can also be made simply by reviewing your Safety Data Sheet (Section 8) to see what the manufacturer’s recommendations are.

Once a hazard that warrants respiratory protection has been discovered, what’s next? OSHA lists the guidelines as to what’s required in a written respiratory program in Section 29 of 1910.134:

1. Respiratory selection

• Understanding the contaminant and its concentration will be key. This will help you determine the appropriate assigned protection factor that fits your needs and what you can use, including air-purifying respirators, powered air-purifying respirators, etc.

2. Hazard identification/concentrations

• Can be done with an industrial hygienist or by purchasing a device that will collect air samples within the work environment in question.

3. Maximum use concentrations

• PEL (permissible exposure limit) x APF (assigned protection factor) = MUC (maximum use concentration)

4. Medical evaluations (Appendix C)

• Can be completed through an online portal or by visiting a physician in person.

5. Initially, prior to issuing a respiratory and fit testing – Fit Testing (Appendix A)

• Required initially and annually
• Whenever there’s a change in respirator or facial features of the user

6. Training and recordkeeping

7. Why, when and where, as well as respirator limitations

8. Procedures for use, inspection, maintenance, cleaning and storage

9. Proper care and use of respirators

10. Routine and emergency use

11. Depending on the type of respirators used

• Filter/cartridge change out schedule and disposal
• Breathing air quality

Implementing a respiratory protection program involves a lot of preparation, planning and maintenance. Many resources are available that can help you establish a program or maintain your current program. First and foremost, OSHA and NIOSH have a wealth of knowledge on their websites. You can always rely on the expertise of the respiratory manufacturer of choice. The important part is to make sure you’re compliant and that your employees go home safe each day.

Editor's note: This article represents the independent views of the author and should not be considered a National Safety Council endorsement.