Editor’s note: This article is the second in a series about the new ANSI/ASSE Z88.2-2015 standard Practices for Respiratory Protection. The first article, which provides an introduction to Z88.2-2015, was published in the September 2015 Synergist.
The respirator program is the starting place for the employer to develop an effective process to safeguard the life and health of respirator wearers, but implementation of respiratory protection programs in the U.S. needs attention. Every year when OSHA publishes the top 10 most frequently cited violations, the respiratory protection standard typically makes it into the top five. In 2014, respiratory protection was the fourth most violated standard, with establishing and implementing a written respiratory protection program as the most cited requirement within the category. The record of quality and compliance of respiratory protection programs in the U.S. private sector is mixed: a 2001 NIOSH survey of respirator use in the private sector found that only 34 percent of establishments that required respirator use had established a written respiratory protection program adopted by management.
Respirator program administrators can avoid becoming one of these statistics by carefully implementing all of the respirator program requirements identified in the ANSI/ASSE Z88.2 Standard, Practices for Respiratory Protection, as appropriate for their workplace (for example, supplied breathing air is not used in all workplaces). A compliant respirator program protects workers’ health, and the industrial hygiene community should be actively involved in understanding and properly implementing their respiratory protection program responsibilities. This article discusses the program administration and evaluation requirements necessary for ensuring that written respiratory protection programs are properly implemented and effective in protecting respirator wearers.
PROGRAM ADMINISTRATION
ANSI and OSHA respiratory protection standards have always been closely correlated. The first six sections of OSHA’s original respiratory protection standard, which was published in the 1970s, were based on ANSI Z88.2-1969. At that time, the agency incorporated ANSI K13.1-1969, Identification of Gas Mask Canisters, as the entire seventh section of the standard. ANSI Z88.2 was updated in 1980 and again in 1992, and greatly influenced the current OSHA Respiratory Protection Standard, 29 CFR 1910.134, which was published in the Federal Register in 1998. As ANSI Z88.2 and OSHA 29 CFR 1910.134 were updated, both retained the basic sound practices set forth in the original standards. The 2015 edition of ANSI Z88.2, which augments OSHA’s standards, is intended to provide industrial hygienists and other health and safety professionals with the best available information on how to develop, implement, and manage a state-of-the-art respiratory protection program.
Unlike the original OSHA standard, the current standard states that a respirator program must be run by a program administrator. OSHA and ANSI are compatible on the policy of permissible practice [see paragraph (a)(1) in 29 CFR 1910.134 and Section 4.2 of Z88.2]. In general, both standards state that exposure to inhalation hazards will be controlled by engineering and administrative controls and that the use of respiratory protection is the final resort when engineering controls do not work, are not feasible, or are being implemented.
An OSHA-compliant respiratory protection program, described in paragraph (c)(3) of 29 CFR 1910.134, requires a qualified program administrator with adequate training and experience to administer the overall program and conduct the required evaluations of its effectiveness. The level of training and experience required of the program administrator must be sufficient to handle the complexity of the respiratory hazards that can be encountered in the workplace. However, the OSHA standard allows the administrator to delegate these responsibilities to others and serve largely in an oversight role for individuals performing duties in support of the respiratory program [see 29 CFR 1910.134(c)]. The program administrator holds the overall responsibility and coordination of the program, but more than one person may play an important role in program administration.
Similar to OSHA’s requirements, Z88.2 requires program administrators to be knowledgeable in respiratory protection and competent in the administration of their duties. They must also keep abreast of current issues, advances, and regulations in respiratory protection (see Z88.2-2015, Section 5.2). Learn more in the sidebar below.
Z88.2 augments OSHA’s requirements in another important way. As required by OSHA, the administrator is responsible for the complete respirator program under Z88.2. However, Section 5.3.1 of Z88.2 details specific responsibilities of the program administrator, including characterization of work areas’ inhalation hazards prior to respirator selection and periodically during respirator use; ensuring that medical evaluations, training, and fit-testing are performed; selecting appropriate respirators for each contaminant, present or anticipated; maintaining records and written procedures documenting the respirator program; evaluating the respirator program’s effectiveness; and revising the program as necessary. The program administrator must ensure that all of these components are properly conducted.
PROGRAM EVALUATION (AUDITS)
Paragraph (l) of OSHA’s respirator standard provides performance-oriented requirements for evaluating workplaces as often as necessary when implementing an effective respirator program. OSHA does not have evaluation frequency requirements and does not require that every program element be evaluated. During program evaluation, employees wearing respirators are consulted to identify and correct any problems with the program; to ensure that there are no problems with respirator usage in the workplace environment such as irritation or breathing resistance; and to ensure proper respirator use in the workplace environment. Other program elements that require evaluation include, but are not limited to, respirator fit-testing; respirator selection; appropriate respirator selection for workplace inhalation hazards; recordkeeping; and respirator maintenance. The program administrator and the employer must correct any problems revealed during this evaluation.
Section 5.3.2 of Z88.2 builds on OSHA’s requirements with a three-tiered approach to respirator program evaluation. The first tier requires ongoing workplace surveillance of respirator use. The second tier requires an annual audit by the program administrator to ensure that written program procedures reflect current applicable regulations and industry-accepted standards, and that the procedures are implemented as written. To aid in the objectivity of the evaluation, an additional third-tier audit is performed by a knowledgeable person other than the program administrator at a frequency based on previous audit results and determined by the size and complexity of the respirator program.
Z88.2 requires a checklist to aid in the program evaluation. At a minimum, this checklist will assess the respirator program and program administration; medical evaluation; respirator training, fit-testing, cleaning, maintenance, and inspection; respirator selection based on air sampling and hazard characterization; respirator issuance, use, and storage; breathing air quantity and quality; emergency preparedness; and special respirator problems. The checklist also addresses corrective action, which shall be taken to correct any defects or shortcomings found during the audit. According to Z88.2, the audit results should be documented along with plans and target dates for correcting problem areas, and tracking mechanisms to ensure completion. IMPROVING AVAILABLE INFORMATION
The AIHA Respiratory Protection Committee conducted a survey of 6,000 AIHA members in May 2011 that identified a much larger than expected number of IHs who are involved in respiratory protection. Sixty-eight percent of the 1,040 survey respondents indicated that their current industrial hygiene job involves managing a respiratory protection program. Forty-six percent said that they are designated as the respirator program manager in their organizations, and 65 percent noted that they are responsible for developing or revising their organizations’ respirator programs. Most surprisingly, 85 percent of respondents answered “yes” to the question, “Do you prescribe respiratory protection for specific work activities?” These survey results indicate that the IH community is a major stakeholder in the content and implementation of the Z88.2 standard on respiratory protection programs.
The Respiratory Protection Committee is planning a new survey to help update and improve the information available from the current IH community on their involvement in respiratory protection. The survey will include specific questions about respiratory protection programs and respirator performance, and provide the opportunity for respondents to identify respiratory protection program issues. A summary of the survey results will be made available to the Z88.2 subcommittee for the next revision of the standard, and will appear in a future Synergist article.
The ANSI Z88 Respiratory Protection Committee is also evaluating a variety of social media tools for their potential to provide a more effective communication mechanism for respiratory protection program issues.
COMMENTS WELCOME
Future articles in this series may focus on assigned protection factors; partnerships among government regulators, employers, employees, and manufacturers to assure effective respiratory protection; limitations on use of particulate respirators with high efficiency particulate filters; oxygen deficiency; and escape respirators. In the meantime, readers’ comments about Z88.2 are welcome. Feedback from practicing industrial hygienists and respiratory protection program administrators will be used in planning updates to the next version of Z88.2, which is scheduled to be published in 2020. Please send comments to Richard W. Metzler at rwmetzler@comcast.net or James S. Johnson at jsjsrj@comcast.net.
DAVID L. SPELCE, MS, CIH (1997–2015), served as the Navy’s respirator expert from 1987 to 2015 and was the Navy’s official liaison to the ANSI Respirator Committee and the ANSI respirator subcommittees. He can be reached at spelce@cox.net.
RICHARD W. METZLER, MSIE, a consultant based in Houston, Pa., is chair of the ANSI/ASSE Z88.2 subcommittee. He can be reached at rwmetzler@comcast.net.
JAMES S. JOHNSON, PhD, CIH, QEP, is a consultant with JSJ and Associates in Pleasanton, Calif., and chair of the ANSI/ASSE Z88 committee. He can be reached at jsjsrj@comcast.net.
TIMOTHY R. REHAK, PE, is a general engineer with the NIOSH National Personal Protective Technology Laboratory (NPPTL) and a member of the ANSI/ASSE Z88.2 subcommittee. He can be reached at ter1@cdc.gov.
The Role of the Respiratory Program Administrator
All past versions of the Z88.2 standard have augmented the OSHA respirator standard, much like the current version of Z88.2. Starting with the 1969 edition, all versions of ANSI Z88.2, including the current standard, require that the responsibility and authority for the respirator program be assigned by senior management to a single person. This person, who is identified to all respirator wearers as the respirator program administrator in the written standard operating procedures, has access and direct communication to the site manager for matters affecting worker safety and health. According to Section 5.1 of Z88.2-2015, a third-party entity is allowed to provide this service, which is especially helpful for employers with small respirator programs.
The Z88.2 program administrator can also have many assistants performing specific elements of the respirator program. For example, the ANSI Z88.2 fit-test operator has a major role in the respirator program. ANSI/AIHA Z88.10-2010, Respirator Fit-Testing Methods, contains comprehensive qualification requirements for the fit-test operator and is devoted to ensuring that proper fit-testing methods are used. Under Z88.2, the program administrator can appoint as many people as necessary to help with various program elements, including the issuing, cleaning, and maintenance of respirators. This delegation of tasks is especially common at large industrial facilities such as shipyards, where it is not feasible for the program administrator alone to perform all the duties required in the program. In vast programs such as these, the program administrator may take on more of an oversight position.
ANSI/AIHA Z88.6-2006, Respiratory Protection – Respirator Use – Physical Qualification for Personnel, is another example of a complex program element requiring such detailed instructions that a separate ANSI respirator standard is required for proper implementation. Z88.6-2006 provides guidance to assist the program administrator and physician or other licensed healthcare professional (PLHCP) in ensuring that respirator wearers are physically and psychologically fit to wear respirators.
RESOURCES
ANSI Z88.2, Practices for Respiratory Protection, sponsored by the United States Bureau of Mines (approved Aug. 11, 1969)
ANSI/ASSE Z88.2, Practices for Respiratory Protection (approved March 4, 2015)
ANSI/AIHA Z88.10, Respirator Fit-Testing Methods (approved Dec. 3, 2010)
ANSI/AIHA Z88.6, Respiratory Protection – Respirator Use – Physical Qualifications for Personnel (approved Aug. 25, 2006)
Federal Register: Occupational Safety and Health Administration, DOL, 29 CFR Parts 1910 and 1926 Respiratory Protection Final Rule, 1998 (Vol. 63, No. 5, Thursday, Jan. 8, 1998)
OSHA Instruction: Inspection Procedures for the Respiratory Protection Standard, Directive Number CPL 02-00-158 (June 26, 2014)
NIOSH, Respirator Usage in Private Sector Firms, 2001, (September 2003)
The Synergist: “Most Cited and Most Necessary” (February 2012)
