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Respiratory Protection Training for Non-Experts
Steps Toward Accessible Respiratory Protection Programs Outside the Industrial Workplace
BY C.R. (GUS) MANNING AND TIM PAZ
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According to NIOSH, before the COVID-19 pandemic, an estimated five million U.S. workers were required to wear respirators on the job. All workers who must wear a respirator, including first responders and healthcare workers, should be able to trust that they are wearing the right respirator and that they have been medically cleared and appropriately trained to use it. This assurance is typically provided by large organizations who maintain respiratory protection programs in compliance with the OSHA respiratory protection standard (29 Code of Federal Regulations 1910.134).
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One effect of the pandemic that has received little coverage is the general public’s unfamiliarity with the principles of respiratory protection, as demonstrated by public discussion about what face masks do and frequent conflation of cloth face coverings with filtering facepiece respirators. Even public officials, medical experts, and other authorities have sometimes proven to be nearly as confused as the public.
This article discusses the problem of developing a more widespread understanding of respiratory protection among the public and workers in small businesses, who are not covered by the respiratory protection standard. AIHA and its members are uniquely qualified to help achieve this goal without the guidance and oversight afforded by a continuous, effective respiratory protection program. If that were easy, it would already be done. Our aim is not to prescribe a simple solution but to seek pathways that may lead toward many solutions.
THE TARGET AUDIENCE The people we wish to reach are those who may need to use a respirator and have minimal training in industrial hygiene. Such persons are common in small businesses and in the general public. Figure 1 depicts the elements of a respiratory protection program typically lacking in small businesses, such as exposure assessment, education and training, and respirator fit testing.
Selecting and using respirators is a complex, technical task that can be difficult for non-experts to understand and perform. Accordingly, in industrial environments, regulations in the U.S. and in many other countries require a formal program administered by a trained person.
Many activities, including construction, sawing and machining, welding, auto repair, woodworking, furniture fabrication, furniture repair, insulation installation, painting, and landscaping, are likely to result in exposures to chemical vapors or aerosols that require respiratory protection. These activities are often undertaken in a small shop or at home by do-it-yourselfers. In either case, people who perform these tasks are subject to the same hazardous exposures as workers in large organizations but without the same safety resources.
During the pandemic, public health officials have urged people to wear cloth face masks to limit the spread of infection. In the minds of many people, mask-wearing intended as source control has become conflated with respiratory protection. As readers of The Synergist are aware, cloth face masks are not respirators and have not been designed to conform to any respiratory protection standard. There is no way to correctly use them as respirators.
Figure 1. Elements of a respiratory protection program typically lacking in small businesses.
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It seems clear that an improvement in public education in respiratory protection leading to correct use must be achieved through a tailored approach that targets small businesses, homeowners, consumers, school-children, and other groups.
We are not the first to recognize ignorance of respiratory protection principles as a national problem. The National Academies of Sciences, Engineering, and Medicine recently formed a committee to study respiratory protection for the public and workers without respiratory protection programs at their workplaces. The NAS website explains that this committee will evaluate means to provide effective and appropriate respiratory protection for people who are exposed to inhalation hazards outside of workplaces with respiratory protection program requirements. Inhalation hazards potentially encountered outside of industrial workplaces include severe air pollution, wildfires, pandemics caused by airborne viruses such as SARS-CoV-2, and other disasters and public health emergencies.
According to the NAS website, the committee will explore “regulatory approaches to meeting respiratory protection needs [. . .] for a broad range of workers who may need to use respiratory protective devices in the absence of a respiratory protection program, as well as for the general public, including vulnerable populations such as children, the elderly, and people with respiratory or cardiovascular disease.” At the time this article went to press, the committee was scheduled to release a report in early February.
COMPLIANCE WITH RESPIRATORY PROTECTION REGULATIONS In the U.S., large organizations typically operate respiratory protection programs in compliance with OSHA’s respiratory protection standard. These requirements include the establishment within each organization of written procedures and administration by experienced and trained individuals. This coverage often does not extend to small and medium-sized businesses and certainly does not extend to uses of respiratory protection outside the workplace.
In December 2013, the Bureau of Labor Statistics (BLS) released a report that analyzed 94,813 inspections of a possible 325,746 industrial facilities that were likely to use respirators. In 40,339 health inspections, BLS found that 22 percent of facilities were cited with violations of the respiratory protection standard. Only about one-third of the inspected facilities were expected to need the use of respirators; therefore, on average, nearly every facility that was using respirators was cited for violations of the respiratory protection standard.
A second study, conducted by NIOSH and published in the Journal of Occupational and Environmental Hygiene in October 2005, found the results of a 2001 survey collected jointly by NIOSH and BLS to suggest that many employers do not follow NIOSH guidance or requirements issued by OSHA or the Mine Safety and Health Administration (MSHA) for the selection and use of respirators. This study also evaluated a 2003–2004 OSHA industry profile to find that across all industries, the number of citations for violating OSHA’s respiratory protection standard were ranked fifth highest out of 378 different citation types. The study’s authors state that the frequency of respiratory protection citations shown in the OSHA data “is consistent with the BLS/NIOSH survey findings that 91 percent of establishments with respirator use had at least one indicator of a potentially inadequate respiratory protection program and 54 percent had at least five such indicators.”
These studies further support the idea that many industrial organizations may not exhibit exemplary compliance with respiratory protection regulations.
While larger organizations may possess resources to establish and maintain a “respiratory protection program” as described by OSHA, small and mid-sized organizations generally lack the services of a trained professional occupational hygienist. For these organizations, compliance with OSHA’s respiratory protection standard and with more recent rules related to COVID-19 can be a daunting challenge.
Due to the complexity of requirements in OSHA’s respiratory protection standard, it is likely that small businesses generally lack the resources and understanding to implement successful respiratory protection programs. If that is so, it seems clear that members of the public who need to use a respirator would be at a greater disadvantage.
ACCESS TO CONSULTING FIRMS As many professional industrial hygienists have noted, the services of IH consulting firms are available to small businesses and the public. However, the costs of employing an industrial hygiene consultant are significant, comparable to consulting with an attorney or accountant. The availability of IH consulting services has not proven effective in educating the public because most people prefer not to consult with a firm before using a respirator in their garage, shop, school, or restaurant. Consequently, the clients of IH consulting firms tend to be medium-sized or larger organizations who can afford these professional services. Most IH consultants cater to their clients and do not take walk-in appointments. Another obstacle is that smaller independent IH consulting firms typically do not maintain a large collection of half- and full-facepiece respirators in various models and sizes as required by OSHA to conduct proper fit testing.
Even if consultants were affordable, their services do not typically include educating the public. People hire lawyers and accountants so they won’t have to learn how to talk to judges or do their own taxes. By following a do-it-yourself approach, people are more likely to gain the actual know-how that will enable them to perform needed tasks now and in the future.
RESPONSES FROM OHS ORGANIZATIONS While online technical support is available from some safety equipment manufacturers, these sites generally assume the user already has a professional level of knowledge about respiratory protection. OSHA has started to address the issue of presenting respiratory protection know-how to non-expert users by publishing simplified respiratory protection training videos on its website.
Other sources of training material are beginning to appear. The International Society for Respiratory Protection (ISRP) has put together a program to provide respiratory protection training in developing countries. The program employs a train-the-trainer approach: ISRP provides instructions to local intermediaries who then present the material to end users. This basic training could readily be spread to other contexts.
The Canadian Centre for Occupational Health and Safety (CCOHS) has published guidance about wearing respirators that includes drawings depicting the proper way to perform a seal check on a disposable respirator and conduct negative and positive pressure fit checks on air-purifying respirators. See Figure 2 for examples of these graphics.
Figure 2. Left to right: checking the seal of a disposable respirator, performing a negative-pressure seal check on a half-mask respirator, and performing a positive-pressure seal check on a half-mask respirator. Reprinted with permission from the Canadian Centre for Occupational Health and Safety: “Respirators—Wearing a Respirator.”
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The goal of “Workplace Health Without Borders” (WHWB), founded in 2011, is to improve general occupational health and safety in developing countries. WHWB produces training modules, and its website links to other training bodies. The organization provides both university-level courses and training at the user level.
Some respirator training materials are available from the Occupational Hygiene Training Association (OHTA). OHTA’s materials come in four experience levels—awareness, foundation, intermediate, and specialist—and some are offered in multiple languages. The organization’s offerings are freely available for use by employers, education and training providers, and professional associations. For more information and other OHTA training materials, visit ohtatraining.org.   AIHA RESPONSE Training materials available through AIHA are generally not accessible to the public or to small or medium-sized businesses that are not AIHA members. The idea that non-expert users can tap into this know-how through consultants is more useful in theory than in practice.
Recently, AIHA published guidelines at backtoworksafely.org to help specific industries reopen following closures brought about by COVID-19. These guidelines provide some technical detail that is accessible to non-technical workplaces and the public. While the information pertaining to respiratory protection information is limited and mixed with information about safety and contamination control, the communication style of the Back to Work Safely documents could be helpful in reaching non-expert respirator users, including the public. The Back to Work Safely site demonstrates how effective this style can be: between the time it was launched in April 2020 and the end of January 2022, backtoworksafely.org had registered over 210,000 page views and more than 3.6 million downloads.
AIHA has the know-how and the resources to address this problem in a more effective manner than other organizations. A current initiative between the AIHA Museum and Cultural Heritage Industry Working Group and the AIHA Respiratory Protection Committee seeks to address a service gap for conservators and collection managers, many of whom manage small work groups with fewer than five employees. This project team is defining the problem, identifying solutions, focusing on a target population, and developing resources to fill a business-to-business (B2B) matchmaking gap, making resources accessible so that consultants providing respiratory protection services can be linked to small businesses in the museum conservator and collection space (see Figure 3). One of these resources, the Respiratory Protection Services Resource List, has been requested by the American Institute for Conservation and will be applicable to small business owners and employees in other industry sectors as well.
Figure 3. AIHA’s Respiratory Protection Resources Project, a collaboration between the Museum and Cultural Heritage Industry Working Group and the AIHA Respiratory Protection Committee, seeks to link consultants who provide respiratory protection services with small businesses in the museum conservator and collection space.
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Federal OEHS agencies and other organizations will be key to the B2B matchmaking effort. The project team has identified a few potential collaborators. The OSHA On-Site Consultation Program, administered by the agency’s Small Business Assistance Office, has a variety of respiratory protection training materials in most state programs. Several NIOSH Education and Resource Centers (ERCs) offer public courses as community outreach and could provide some of the training needed by small businesses that lack in-house IH expertise. Perhaps the ERCs could adapt a respirator training course for small businesses or sole proprietors. Similarly, NIOSH’s National Personal Protective Technology Laboratory (NPPTL) maintains a library of etools and other training materials. The American College of Occupational and Environmental Medicine (ACOEM) could identify occupational medicine and ambulatory clinics that provide OSHA-compliant medical evaluation services. Finally, the project team also plans to survey the AIHA Consultants Listing and AIHA local sections to identify practitioners who can conduct training and fit testing.
To prevent published respiratory protection information from overwhelming the target audience, the project will use a “sensemaking approach,” as described in a recent article in the Harvard Business Review, which emphasizes simplicity over comprehensiveness and provides just enough information for meaningful learning. Connecting the audience with relevant resources and clarifying information in a collaborative manner may help non-experts feel empowered to grasp technical information and hire the services needed to protect the respiratory health of their employees.
GENERAL PATHWAYS TO SOLUTIONS The programs discussed in this article are generally moving toward presentation of respiratory protection training to the target audience. However, many initiatives still have shortcomings, including:
  • lack of a robust media platform on which to present information
  • difficulty in overcoming the problem of designing training materials sufficiently rigorous to teach the basics, yet understandable by the target audience
  • lack of intermediary trainers to pass on the training
Training materials alone do not provide a solution to educating the public with respect to the correct use of respirators. Going forward, better respiratory protection training programs may use specific examples, storytelling, illustrations, and simplified instructions to present material that provides adequate technical depth and breadth while still being accessible to the target audience. Material could be presented via slideshows, audio and video recordings, DVDs, websites, printed cards, booklets, and signs posted throughout workplaces. In addition to in-person presentations, organizations can make use of podcasts, livestreaming services, mailing lists, television and radio ads, and even billboards as media to transmit information on respiratory protection.
CALL TO ACTION Viable training materials should stress the importance of exposure assessments and the use of engineering controls before considering the selection and use of respirators. We must also remember to educate small businesses and the public on the proper sequence of the required program elements: the performance of medical evaluations followed by education and training in correct respirator use, and then respirator fit testing.
The general public and employees working for small businesses deserve protection from respiratory hazards but generally lack the resources and understanding required to implement an effective respiratory protection program. We, the industrial hygiene community, must take a leadership role and address this problem.
If we don’t step up and help, who will?
C.R. (GUS) MANNING, PhD, CIH, FAIHA, is founder and CEO of Assay Technology and chair of the AIHA Respiratory Protection Committee.
TIM PAZ, CIH, is a senior industrial hygienist at the Federal Emergency Management Agency in Washington, D.C.
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RESOURCES
AIHA: “Back to Work Safely.”
Bureau of Labor Statistics: Monthly Labor Review, “Using OSHA Inspection Data to Analyze Respirator Protection Program Completion” (December 2013).
Canadian Centre for Occupational Health and Safety: “OSH Answers Fact Sheets—Respirators—Wearing a Respirator.”
Harvard Business Review: “Sensemaking for Sales” (January 2022).
International Society for Respiratory Protection: Basic Training Program – Personal Breathing Protection (PDF, 2007).
International Society for Respiratory Protection: “ISRP Training Program – Developing Countries.”
Journal of Occupational and Environmental Hygiene: “A Survey of Private Sector Respirator Use in the United States: An Overview of the Findings” (October 2005).
National Academies Press: Measuring Respirator Use in the Workplace (2007).
National Academies of Sciences, Engineering, and Medicine: “Respiratory Protection for the Public and Workers Without Respiratory Protection Programs at Their Workplaces.”
NIOSH: National Personal Protective Technology Laboratory.
Occupational Hygiene Training Association: “Find Training Materials.”
OSHA: “On-Site Consultation.”
OSHA: “Respiratory Protection Training Videos.”
Workplace Health Without Borders: “Training – Seventeen Countries, Three Languages, 48 Participants” (April 2021).