PHOTOS Top left: CC-SCBA hands-on training. Photo courtesy of Biomarine Inc. Top right: Ebola response. Photo courtesy of CDC.
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.
Z88.2 and the Effective Respirator Program
Respiratory Protection
First Line of