OSHA’s regulation 1910.134 covers respiratory protection. OSHA requires employers to provide their employees with respirators that are “applicable and suitable for the purpose intended.” Different types of air contaminants require different types of respirators. OSHA requires that the correct type of respirator be provided, so that the respirator protects against the respiratory hazards that are actually present.
OSHA 1910.134 also requires that respirators be provided any time “when such equipment is necessary to protect the health of the employee.” There are no exceptions. Employees cannot be required to use their own respiratory protection devices, or decide for themselves when respiratory protection is needed.
It is the employer's responsibility to identify hazards and determine that respiratory protection is required, and it is the employer's responsibility to provide the correct respiratory protection. If the type of respiratory hazard cannot be specifically identified or reasonably estimated, then the employer must treat the condition as being immediately dangerous to life or health (IDLH), and supply an appropriate respirator.
Respirators are categorized and certified by the National Institute for Occupational Safety and Health (NIOSH).
All employees who will be using a respirator must have a medical evaluation paid for by the employer. If an employee refuses to have the medical evaluation, they may not perform the work for which a respirator is required.
The purpose of the medical evaluation is to determine whether or not the employee is able to use a respirator. The evaluation is performed using a medical questionnaire provided by OSHA in Appendix C of 1910.134, or by a physical exam that collects the same information as the medical questionnaire. The licensed health care profession who does the evaluation then provides a written recommendation concerning each employee's ability to use a respirator.
If either a negative or positive pressure tight-fitting facepiece respirator is used, the employee must pass an appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT) before the respirator is used. A fit test must also be conducted:
- at least annually;
- whenever a different respirator face piece is used;
- whenever the employee reports changes in their physical condition that could affect respirator fit;
- whenever the employer observes changes in the employee’s physical condition that could affect respirator fit, such as facial scarring, dental changes, cosmetic surgery, and obvious change in body weight.
Use of Respirators
There are some obvious restrictions on the use of respirators. For example, employees with facial hair, or any other condition that could interfere with the seal or valve operation, may not use a tight-fitting respirator. The employer does not need to prove there is a problem; it can be assumed.
Also, care must be taken with PPE. If additional PPE (in addition to the respirator) is required, it must be worn in a way such that it does not interfere with the seal or the faceplate of the respirator.
When using a tight-fitting respirator, the employee is required to perform a seal check each time they put on the respirator. The mandatory seal check procedure is given in OSHA 1910.134 Appendix B-1.
Maintenance and Care of Respirators
One of the basic maintenance requirements is that respirators must be cleaned and disinfected:
- as often as necessary to maintain a sanitary condition, for exclusive-use respirators.
- before being worn by different individuals, when issued to more than one employee.
- after each use, when the respirator is an emergency-use respirator, or one that is used for fit testing and training.
In addition, respirators should be regularly inspected for damage and wear that might affect their effectiveness.
Some respirators use filters, cartridges, or canisters. These must be identified with color-coded NIOSH approved labels. If labels are missing or are not legible, the filter, cartridge or canister must not be used.
OSHA 1910.134 requires that employers provide effective training for those who need to use respirators. That training must include explaining:
- Why the respirator is necessary.
- How improper fit, use, or maintenance can compromise the protection provided by a respirator.
- The limitations and capabilities of the respirator.
- How to do the following:
- Use a respirator in emergency situations.
- Inspect a respirator.
- Put on and remove a respirator.
- How to check the respirator's seals.
- How to maintain and store a respirator.
- The medical signs and symptoms that may limit or prevent the effective use of a respirator, and how they can be spotted.
- The general requirements of the OSHA 1910.134 standard.
Training must be provided by the employer:
- Prior to the initial use of respirators, unless documented acceptable training has been provided by another employer within the past 12 months.
- At least annually.
- Any time when workplace conditions change, a new type of respirator is used, orthere is any indication that an employee needs respirator training.