Hazard Assessment

HAZARD ASSESSMENT and RESPIRATORY PROTECTION

1. CORPORATE POLICY, REQUIREMENTS AND PROCEDURES

1.1. Purpose – To establish the requirements and procedures to protect employees against overexposure to airborne contaminants.

1.2. Definitions

A. Air-purifying Respirator – A respirator with an air-purifying filter, cartridge, or canister that removes specific air contaminants by passing ambient air through the air-purifying element.

B. Atmosphere-supplying Respirator – A respirator that supplies the respirator user with breathing air from a source independent of the ambient atmosphere, and includes supplied-air respirators (SARs) and self-contained breathing apparatus (SCBA) units.

C. Canister or Cartridge – A container with a filter, sorbent or catalyst, or combination of these items, which removes specific contaminants from the air passed through the container.

D. Filtering Facepiece (dust mask) – A negative pressure particulate respirator with a filter as an integral part of the facepiece or with the entire facepiece composed of the filtering medium.

E. Fit Test – The use of a protocol to qualitatively or quantitatively evaluate the fit of a respirator on an individual.

F. Immediately Dangerous to Life or Health (IDLH) – An atmosphere that poses an immediate threat to life, would cause irreversible adverse health effects, or would impair an individual’s ability to escape from a dangerous atmosphere.

G. Negative Pressure Respirator (tight fitting) – A respirator in which the air pressure inside the facepiece is negative during inhalation with respect to the ambient air pressure outside the respirator.

H. Positive Pressure Respirator – A respirator in which the pressure inside the respiratory inlet covering exceeds the ambient air pressure outside the respirator.

I. Qualitative Fit Test (QLFT) – A pass/fail fit test to assess the adequacy of respirator fit that relies on the individual’s response to the test agent.

J. Quantitative Fit Test (QNFT) – An assessment of the adequacy of respirator fit by numerically measuring the amount of leakage into the respirator.

NPCA Guide to Plant Safety 7/19/02

1 HAZARD ASSESSMENT and RESPIRATORY PROTECTION

K. Self-contained Breathing Apparatus (SCBA) – An atmosphere- supplying respirator for which the breathing air source is designed to be carried by the user.

L. Supplied-air Respirator (SAR) or Airline Respirator – An atmosphere-supplying respirator for which the source of breathing air is not designed to be carried by the user.

M. User Seal Check – An action conducted by the respirator user to determine if the respirator is properly seated to the face.

1.3. Determination of Airborne Contaminant Exposure – Monitoring of the work place should be conducted as often as necessary to determine if a level of airborne contaminants are present, which may impact the health of employees working in that area.

 Each plant manager or his designee should:

. Analyze the various jobs being performed at his/her respective location. . Determine if a level of airborne contaminants is present, which may impact the health of employees working in each area where the various jobs are being performed. . Select and/or purchase proper respiratory protective equipment necessary to provide adequate protection against the hazards identified for each of the various jobs being performed at his/her respective location. (This should be based on the evaluation and recommendations of the Safety Department.) . Ensure that all required respiratory protective equipment is available, appropriate and well maintained.

1.4. Airborne Contaminant Exposure (Engineering Controls) – Airborne contaminant levels exceeding threshold limit values (TLV’s) should first be reduced as much as possible through engineering controls. Examples of engineering controls are:

A. Enclosing existing equipment cabs or installing new ones. B. Enclosing spouts in screening, mixing, bagging and other operations where cement, sand, rock or other dusty materials are dumped, where practical. C. Installing water, mist or fog sprays to prevent dust from escaping at the source; such as roads, screening equipment, bagging equipment, mixing equipment and transfer points, where practical.

D. Installing dust collection systems to prevent dust from escaping at the source; such as screening equipment, bagging equipment, mixing equipment and transfer points, where practical. E. Using ventilation devices.

1.5. Respiratory Protection – Employees working in potentially hazardous breathing environments must be supplied with respiratory protection.

A. Use of respiratory protection must be mandatory in designated areas when:

 Engineering controls are not feasible.  During such time as engineering controls are being implemented, but are not complete.  Working in posted areas.

B. Appropriate respiratory protection must be available from the Company. Employees must be instructed in the proper selection and use of respiratory protection.

1.6. Selection – Respirators should be selected which have been tested and approved by NIOSH for protection against the known hazard. The range of respirators available should be adequate to accommodate the physical characteristics of the employees to be fitted.

A. The three filter series are referred to as N,R and P. The levels of filter efficiency are 95 percent, 99 percent and 99.9 percent against the most difficult size particle to filter.

 N-Series Filters – the “N” refers to “no oil in the air.” This filter may be used for solid or liquid particulate hazards that do not contain oil and where the hazard is only the particulate nature of the contaminant. Generally, these filters can be used and reused subject only to considerations of hygiene, damage and increased breathing resistance.

 R-Series Filters – the “R” refers to “oil resistant.” This filter provides some protection against air that is contaminated with some particulate and has some oil present; however, this filter is not the best alternative. This filter may be used for any solid or liquid airborne particulate hazard. If the atmosphere contains oil, this filter can only be used for a single shift or eight hours of continuous or intermittent use.

 P-Series Filters – the “P” refers to “oil proof.” This filter is intended for removal of any particulate, including oil-based

liquid aerosols. This filter may be used for any solid or liquid particulate airborne hazard. Typical service life should not exceed 40 hours of continuous use or 30 days of intermittent use, unless hygiene or other reasons warrant earlier replacement.

B. Where oil is suspected, but air samples have not been taken to determine its presence, a “P” series filter should be selected.

1.7. Training – Employees must be trained in the proper use of respirators and their limitations.

A. The employees must be instructed in the nature of the hazard and an appraisal of what may happen if the respirator is not worn as required. Training will provide employees with the opportunity to handle a respirator and have it properly fitted, to test its face seal, and to wear it in normal air for familiarization. This training must also include how to properly don, doff, adjust and wear a respirator; the limitations of the respirator; and the proper care, maintenance, useful life and disposal of the respirator.

B. This training must include a process by which each employee demonstrates an understanding of the training provided and demonstrate the ability to use the respirator properly, before an employee is allowed to perform work requiring the use of a respirator.

 In cases where management does not believe that an employee has adequate understanding and ability, the employee should receive additional training.

C. On hire and annually thereafter, affected employees must be trained in the proper use of respirators.

1.8. Posting

A. Areas where employees are required to wear respiratory protection due to the presence of a potentially hazardous breathing environment must have a sign posted which will be visible from the work area. (See Example 1.)

1.9. Monitoring and Enforcement – Safety personnel and/or supervisors should monitor and enforce the wearing of respiratory protection and will post signs in areas where hazardous breathing environments exist.

Monitoring of the work place should be conducted as often as necessary to determine if hazardous breathing conditions exist, and to determine the adequacy of any control measures being used. Employees who refuse to wear respiratory protection must not be allowed to work in exposed areas.

1.10. Assessment

A. General guidelines must be followed when assessing respiratory hazards that exist in the workplace and when matching respiratory protection equipment to the particular hazards found. It should be the responsibility of the plant manager, with the assistance of the Safety Department, to select the appropriate respiratory protection equipment based on the particular hazards found during the assessment of a site.

B. The plant manager or his designee must verify that the required workplace hazard assessment has been performed through a written certification that identifies:

 The workplace evaluated.  The name of the person certifying that the evaluation has been performed.  The date(s) of the hazard assessment.  The document as a certification of hazard assessment.

. Refer to the “Workplace Hazard Assessment Certification Form” included in this section.

C. The following procedure should be followed in assessing workplace hazards:

 Conduct a walk-through survey of all work areas, giving consideration to harmful dust or inhalants.

 During the walk-through survey, observations must be made as to the sources of harmful dust or inhalants.

 During the walk-through survey, monitoring of the work place must be conducted to determine if levels of airborne contaminants are present that exceed the threshold limit values (TLV’s).

 In addition to the walk-through, all respiratory illness records should be reviewed to help identify possible problem areas.

D. Upon completion of the walk-through, monitoring, and review of records, all information should be organized and reviewed in order to best determine all possible hazards in the work place and to best select respiratory protection equipment to protect against those hazards.

E. The selection of required respiratory protection equipment can be documented on the form entitled “Worksite-Specific Respirator Plan,” included in this section and the form entitled, “Job-Specific Personal Protective Equipment Requirements,” included in Part III, Hazard Assessment and Personal Protection Equipment.

1.11. Sample Respiratory Protection Policy and Procedures

A. All employees working in a potentially hazardous breathing environment will have access to respiratory protection.

B. All employees working in potentially hazardous breathing environments are required to have their respiratory protection immediately available while on site.

C. Respiratory protection is available at the job-site offices or from supervisors.

D. Respiratory protection must be worn while working in potentially hazardous breathing environments.

E. All employees using respiratory protection must use their respiratory protection in accordance with instructions and training received.

F. If the necessity of wearing respiratory protection is in doubt, respiratory protection should be worn until such time as an accurate evaluation indicates that the environment is not a hazardous breathing environment.

G. All employees having the need to wear respiratory protection will be certified as medically qualified to wear a respirator and then fit tested prior to wearing a respirator.

H. Since beard growth (including “stubble”) prevents an effective seal, all persons who are required to wear a respirator must be clean-shaven over the skin surface that seals against the face piece of the respirator, unless the person is fitted with an approved hood type respirator.

I. Each time an employee puts on a tight-fitting respirator, he/she must perform a user seal check on the respirator.

J. When respiratory protection is used in IDLH atmospheres, the presence of at least one other person with back-up equipment and rescue capability must be required.

1.12. Medical Certification

A. The Company should allow voluntary use of respirators by employees who by definition are not exposed to hazardous breathing environments, but who based on their own personal comfort level believe a respirator affords them additional comfort and/or protection. These employees should be allowed to wear a respirator after:

 It has been determined that the use of the respirator will not in itself create a hazard.  It has been determined that the employee is medically qualified to wear a respirator. (Filtering facepiece exempt from requirement.)  The employee has received a copy of 29 CFR 1910.134, Appendix D (included in this section).

B. The Company must require all employees exposed to hazardous breathing environments to be certified as medically qualified to wear a respirator prior to being fit tested for a respirator.

C. Medical qualification must be certified by the following medical evaluation procedure:

 Company should obtain the services of a physician or other licensed health care professional to perform the medical qualification evaluation using either a medical questionnaire – Sections 1 and 2, Part A of Appendix C of 29 CFR 1910.134 or a medical examination.  Employee must undergo the medical evaluation.  Any employee responding positively to any question among questions one through eight of the questionnaire, or who demonstrates the need for a follow-up medical examination as a result of the initial medical examination, must undergo a follow-up medical examination.  The follow-up medical examination should include any medical tests, consultations or diagnostic procedures that the administering physician or licensed health care professional

deems necessary to make the final determination of medical qualification.  Only employees that are certified as medically qualified to wear a respirator should be eligible for fit testing and respirator use.

D. The Company should require subsequent medical qualification evaluations for an employee who has been deemed medically qualified to wear a respirator, for any of the following reasons:

 Employee reports medical signs or symptoms that are related to his/her ability to use a respirator.  A physician, licensed health care professional or supervisor informs the Company that an employee needs to be reevaluated.  Information from the respiratory protection program, including observations made during fit testing and program evaluation, indicates a need for employee reevaluation.

1.13. Fit Testing

A. The Company requires all employees exposed to potentially hazardous breathing environments to be fit tested with the same make, model, style and size of respirator that will be used, prior to wearing a respirator.

 Fit testing must conform to OSHA-accepted fit test protocols found in Appendix A of 29 CFR 1910.134.

1.14. Respirator Maintenance – Respirators must be cleaned and disinfected regularly. The maintenance program can be adjusted according to the type and size of the operation where respirators are to be worn. A minimum program must include cleaning, inspection for defects and repair. Respirators should be cleaned after each day’s use. Whenever possible, a respirator should be assigned to each worker for his/her exclusive use.

A. The Company must provide training describing acceptable respirator cleaning and maintenance procedures for each employee required to use respiratory protection.

B. The following procedure shhould be followed when cleaning and maintaining respirators:

 Remove and discard filters.

 Wash face piece in a detergent/disinfectant solution (warm temperature at 140o F).  Rinse face piece completely in clean warm water.  Air dry in a clean area.  Inspect valves, head straps and other parts.  Replace defective parts with NIOSH-approved parts designed for the respirator.  Insert new filters, making sure correct filters are used and the seal is tight.  Place assembled respirator in plastic bag for storage.

1.15. Record Keeping

A. The plant manager or his designee must maintain all records including assessment, respirator selection, medical certification, fit testing and training records.

B. Training may be documented by means of “Training Documentation Forms” and/or “Safety Meeting Forms” and a copy must be placed in each employee’s file (see Part III, Training). Training records should be retained for a period of three years from the date of the training and must include the following information:

 Employee’s name.  Date of training.  Outline describing the training material.  Signature of trainer documenting that training was provided.  Signature of employee documenting that training was received.

C. The plant manager or his designee should verify the required respiratory protective equipment for each job within the workplace by completing, dating and signing the form entitled “Worksite- Specific Respirator Plan,” included in this section and the form entitled, “Job Specific Personal Protective Equipment Requirements,” included in Part III, Hazard Assessment and Personal Protection Equipment.

D. The plant manager or his designee should verify that the required workplace hazard assessment has been performed by completing, dating and signing the written certification form entitled, “Workplace Hazard Assessment Certification Form.”

2. STATUTORY REFERENCES

2.1. 29 CFR § 1910.134 - Respiratory Protection.

2.2. 29 CFR § 1910.134 App B-1 - User Seal Check Procedures.

2.3. 29 CFR § 1910.134 App B-2 - Respiratory Cleaning Procedures.

2.4. 29 CFR § 1910.134 App C - OSHA Respirator Medical Evaluation Questionnaire.

2.5. 29 CFR § 1910.134 App D - Information for Employees Using Respirators When not Required Under Standard.

RESPIRATOR Y PROTECTION REQUIRED WHEN ENTERING THIS AREA

EXAMPLE 1

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Appendix D to Sec. 1910.134

(Mandatory) Information for Employees Using Respirators When Not Required Under the Standard

Respirators are an effective method of protection against designated hazards when properly selected and worn. Respirator use is encouraged, even when exposures are below the exposure limit, to provide an additional level of comfort and protection for workers. However, if a respirator is used improperly or not kept clean, the respirator itself can become a hazard to the worker. Sometimes, workers may wear respirators to avoid exposures to hazards, even if the amount of hazardous substance does not exceed the limits set by OSHA standards. If your employer provides respirators for your voluntary use, of if you provide your own respirator, you need to take certain precautions to be sure that the respirator itself does not present a hazard.

You should do the following:

1. Read and heed all instructions provided by the manufacturer on use, maintenance, cleaning and care, and warnings regarding the respirators limitations.

2. Choose respirators certified for use to protect against the contaminant of concern. NIOSH, the National Institute for Occupational Safety and Health of the U.S. Department of Health and Human Services, certifies respirators. A label or statement of certification should appear on the respirator or respirator packaging. It will tell you what the respirator is designed for and how much it will protect you.

3. Do not wear your respirator into atmospheres containing contaminants for which your respirator is not designed to protect against. For example, a respirator designed to filter dust particles will not protect you against gases, vapors, or very small solid particles of fumes or smoke.

4. Keep track of your respirator so that you do not mistakenly use someone else's respirator.

[63 FR 1152, Jan. 8, 1998; 63 FR 20098, April 23, 1998]

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