I Respiratory Protection Program Table of Contents Section Title Page 1.0 Purpose 2 2.0 Scope and Application 2 3.0 Responsibilities 3 Program Administrator 3 Dept. Heads, Supervisors 3 Employees 4 4.0 Program Elements 4 Selection Procedures 4 Updating the Hazard Assessment 5 NIOSH Certification 5 Voluntary Respirator Use 5 Medical Evaluation 6 Fit Testing 7 Respirator Use 7 General Use Procedures 7 Emergency Procedures 8 Respirator Malfunction 8 IDLH Procedures 8 Cleaning, Maintenance, Storage 9 Training 10 5.0 Program Evaluation 11 6.0 Documentation and Record keeping 11 1
RESPIRATORY PROTECTION PROGRAM 1.0 Purpose Western University of has determined that employees in the Embalming Room within the Anatomy Laboratory are exposed to respiratory hazards during routine operations. These hazards include fumes and vapors that may in some cases, present situations which may represent Immediately Dangerous to Life or Health (IDLH) conditions. The purpose of this program is to ensure that all employees in this identified area are protected from exposure to respiratory hazards. Engineering controls, such as ventilation and substitution of less dangerous chemicals, are the first line defense; however, engineering controls have not completely controlled potential exposures in the area identified. Respirators and other protective equipment must be used to ensure employee safety and health. The work process requiring respirator use in the Embalming Area is outlined in Section 2.0 Scope and Application. Additionally, some employees may elect to voluntarily use respirators during certain operations that do not require respiratory protection. These include but are not limited to maintenance and facilities support operations such as painting (latex paint), woodworking and sanding. As general policy, the University will review each of these on a case by case basis. If a respirator in a specific case will not jeopardize the health or safety of the worker(s), the University will provide respirators for voluntary use. Voluntary use is subject to certain requirements of this program as outlined in the Scope and Application Section of this program. 2.0 Scope and Application This program applies to all employees who are required to wear respirators during normal work operations. This includes the embalming operations within the Anatomy Laboratory. Respective employees are required to follow this written program and applicable rules and regulations. Any employee who voluntarily wears a respirator when the respirator is not required, (i.e. in certain maintenance and facilities operations or projects) is subject to the medical evaluation, cleaning, maintenance, and storage elements of this program, and must be provided with certain information specified in this section of the program. Employees who voluntarily wear filtering face pieces (dust masks) are not subject to the medical evaluation, cleaning, storage, and maintenance provisions of this program. Employees participating in the program do so at no cost to them. The expense associated with the training, medical evaluations and equipment will be borne by the University. 2
Voluntary and Required Respirator Use Respirator Filtering Dust Mask Full face Department/Process Voluntary for maintenance/facilities Embalming operations 3.0 Responsibilities Program Administrator The Program Administrator is responsible for administering the program. Duties include: Identify work areas, processes or tasks that require employees to wear respirators, and evaluating hazards. Selection of respiratory protection options. Monitor respirator use to ensure respirators are used in accordance with their certifications. Arranging for and/or conducting training. Ensuring proper storage and maintenance of respiratory protection equipment. Conducting qualitative fit testing with Bitrex. Administering the medical surveillance program. Maintaining records required by the program. Evaluating the program. Updating the program as needed. The Program Administrator at the University is Ron Redden, University Safety Coordinator. Department Heads, Supervisors The personnel are responsible for ensuring that the program is implemented in their particular areas of responsibility. They must be knowledgeable of the program contents and requirements as well as enforcing the implementation of the program. Their specific duties include: Ensuring that employees under their supervision have received proper training, fit testing, and annual medical evaluation. Ensure the availability of appropriate respirators and accessories. 3
Being aware of tasks requiring the use of respirators. Enforcing the use of respiratory protection when necessary. Ensure that respirators and associated equipment is properly cleaned and maintained. Ensure that respiratory protection fits properly. Continually monitor work areas and operations to identify respiratory hazards. Coordinating with the Program Administrator on how to properly address respiratory hazards or other concerns regarding the program. Employees Each employee has the responsibility to wear their respirator when and where required and in the manner in which they were trained. Employees must also: Care for and maintain their respirators as instructed, and store them in a clean, sanitary location. Inform their department head or Supervisor if the respirator no longer fits properly, and request a new unit that fits properly. Inform their department head or Supervisor of any respirator hazards that they feel are not adequately protected against or addressed, and any other concerns they have regarding this program. 4.0 Program Elements Selection Procedures The Program Administrator will select respirators and associated equipment based upon the hazards to which employees are exposed and in accordance with applicable safety regulations. The Administrator will conduct a hazard evaluation of each area, operation or process where air borne contaminants may be present in routine operations or during an emergency. The hazard evaluation will include: Identification and development of a list of hazardous substances used in the workplace, department or process. 4
Review of processes to determine where potential exposures to these hazardous substances occur. The review will be conducted by surveying the area, reviewing the operational records, and talking with department heads, Supervisors, and employees. Exposure monitoring will be completed to quantify potential hazardous exposures. Monitoring will be completed by a Certified Industrial Hygienist and samples will be analyzed by an accredited laboratory. Updating the Hazard Assessment The Administrator must revise and update the hazard assessment as needed (i.e. any time the work process changes or introduces new potentially hazardous materials which may be affected by respiratory protection needs). If an employee feels that they need a respirator, that employee must contact their department head or Supervisor who will in turn, request the Administrator to perform an evaluation and if necessary, air monitoring as necessary to determine if exposure exists. If it is determined that respiratory protection is required, the Administrator will provide all elements of this program to the requesting employee. NIOSH Certification All respirators used at the University will be certified by the National Institute for Occupational Health and Safety (NIOSH) and shall be used in accordance with the terms of that certification. Also, all filters, cartridges, and canisters must be labeled with the appropriate NIOSH label that cannot be removed, defaced or altered while it is in use. Voluntary Respirator Use The University will provide respirators at no charge to employees for voluntary use for the following processes: Maintenance/facilities painting, woodworking or wood sanding. Welding or torch cutting under approved hoods. Laboratory personnel handing chemicals when exposure has been deemed to be non-existent by sampling, or adequate protection has been provided by engineering means (fume hoods, exhaust ventilation, etc.). The Administrator will provide employees who choose to voluntarily wear respiratory protection with the appropriate section(s) of this program. Employees who choose to wear a half-face respirator must comply with the requirements for Medical Evaluation, Respirator use and Cleaning, Storage and Maintenance. 5
The Administrator will authorize voluntary use of respirators as requested by all other employees on a case-by-case basis, depending upon specific workplace consultations and the results of medical examinations. Medical Evaluation Those employees who are required to wear respiratory protection, or those who choose to voluntarily wear an APR, must pass a medical exam before being permitted to wear a respirator on the job. They are not permitted to wear the respiratory protection until a physician has determined that they are medically able to do so. Any employee refusing a medical evaluation for respirator use will not be allowed to work in any area requiring respirator use. A licensed physician at a clinic selected by the university will provide the medical evaluations. The medical evaluation procedure is: The evaluation will be conducted using the questionnaire provided in Appendix C of the OSHA standard. The Administrator will provide a copy of this questionnaire to all employees requiring medical evaluations. It is permissible for the clinic to also provide the questionnaire at the time of the actual medical evaluation. All affected employees will be given a copy of the questionnaire to complete plus a self-addressed, stamped envelop for mailing the questionnaire to the clinic. The questionnaire may be completed while at work, on paid time. Follow-up medical exams will be granted to employees as required by this program and the OSHA standard, or as deemed necessary by the university physician. All employees can discuss with the physician the results of their medical evaluation. The clinic has been provided with a copy of this program. The clinic has a copy of the OSHA standard and a list of hazardous materials used at the University. The affected employee(s) profile containing department, operation description, title, physical work load, potential temperature and humidity extremes, and any other protective equipment or clothing required to be worn by the employee. After the employee has received medical clearance and begins to wear the respirator, additional medical evaluations will be provided under the following circumstances: Employee reports signs/symptoms related to their ability to use a respirator, such as shortness of breath, dizziness, chest pains, or wheezing. The clinic physician informs the Administrator that the employee needs to be reevaluated. Information in this program, including observations made during fit testing or program evaluation, indicates a need for reevaluation. 6
A change occurs in the workplace that may result in an increased physiological burden on the employee. A list of employees currently included in the Medical Surveillance Program is provided in Section 4 Respirator Use of this program. All examinations and questionnaires remain confidential between the employee and the physician. The clinic retains all respective medical records. Fit Testing Fit testing is required for employees wearing half or full face respirators. Employees who voluntarily wear APRs may also be fit tested upon their request. Employees who are required to wear the above forms of respiratory protection will be fit tested: Prior to being allowed use of any respirator with a tight fitting face piece. Annually When there are changes in the employee s physical condition that could affect respiratory fit (e.g. body weight, facial scarring, extreme facial hair, etc.). Employees will be fit tested with the make, model, and size of respirator they will actually use. Employees will be provided with several models and sizes so that they find the optimal fit. The Administrator will conduct fit tests following the OSHA approved Bitrex Solution Aerosol QLFT Protocol found in Appendix B (B4) of the Respiratory Protection Standard. It is acceptable for the Administrator to use qualified outside contractors to conduct fit testing. Respirator Use Respiratory protection is required for the following personnel: Name Department Job Description Respirator XXXXXXX Embalming Embalmer Full Face General Use Procedures Employees will use respirators under conditions specified by the program, and in accordance with the training they receive on the use of each particular model. The 7
respirator will not be used in a manner for which it is not certified by NIOSH or by the manufacturer. All employees shall conduct user seal checks each time that they wear the respirator. They shall use either the positive or negative pressure check as described in Appendix B-1 of the OSHA Respiratory protection Standard. All employees shall be permitted to leave the work area to maintain their respirator whenever the employee deems it necessary. Employees are not permitted to wear tight fitting respirators if they have any condition, such as facial scars, facial hair, missing dentures, etc. that prevents them from achieving a good seal. Employees are not permitted to wear or use headphones, jewelry, or other articles that may interfere with the face-piece-to-face seal. Emergency Procedures The following work area has been identified as having foreseeable emergencies: Embalming Room Major spill of embalming fluids or component fluids. If such a spill occurs, the embalmer or person in-charge at the time of the spill will clear the room and adjacent laboratory of all personnel. The call to 911 and the University Security line will be made by the person in-charge at the time of the spill. The University Emergency Plan will be activated upon notification of the spill. Respirator Malfunction Any malfunction of the respirators being used will be cause for the employee to report this to their supervisor. The Administrator will provide a new respirator of similar model and type to the employee. The malfunctioning respirator will be returned to the manufacturer or supplier for repair or replacement. IDLH Procedures The Administrator has identified the following area as presenting the potential for IDLH conditions: Embalming Room The Administrator will provide periodic air monitoring of fumes and vapors in this room, at least once per calendar year to ensure exposure levels have not changes. Additionally, specific emergency procedures for a chemical spill, fire exposure and other emergency conditions involving this area have been developed and are posted in the department. Department personnel have received training in these procedures. 8
Cleaning, Maintenance, Change Schedules and Storage Cleaning Respirators are to be regularly cleaned and disinfected at the designated respirator cleaning area located outside the embalming room. Respirators issued for the exclusive use of an employee shall be cleaned as often as necessary, but at least once a day for employees in the embalming room. The following procedure will be used when cleaning and disinfecting respirators: Disassemble respirator, removing any filters, canisters or cartridges. Wash the face piece and associated parts in mild detergent with warm water. Do not use organic solvent for cleaning. Rinse completely in clean warm water. Wipe thew respirator with disinfectant wipes (70% isopropyl alcohol) to kill germs. Air dry in a clean area. Reassemble the respirator and replace any defective part(s). Place in a clean, dry plastic bag or other air-tight container. Maintenance Respirators are to be maintained at all times in order to ensure proper function and adequate protection for the employee. Maintenance involves a complete visual inspection for cleanliness and defects. Worn or deteriorated parts will be replaced prior to use. No repairs nor replacements will be made beyond those recommended by the manufacturer. The following checklist items will be used when inspecting respirators: Face piece Cracks, tears, or holes Facemask distortion Cracked or loose lenses/faceshield Headstraps Breaks or tears 9
Valves Broken buckles Residue or dirt Cracks or tears in valve material Filters/Cartridges Approval designation Gaskets Cracks or dents in housings Proper cartridge for hazard Cartridges will be changed according to manufacturer s recommendations or more often. Storage Respirators will be stored in a dry, clean area, in accordance with manufacturer s recommendations. The employee will clean and inspect their own respirator and will store that respirator in an airtight bag in a safe designated area. The employee name will be one the respirator storage bag. Spare parts and respirator components, as well as replacement respirators, will be stored in a safe area, in the manufacturer s containers. Defective Respirators Respirators that are defective, or have defective parts, will be removed from service immediately, tagged as defective, and returned to the supplier or manufacture for repair. Replacement respirators will be provided, identical to the unit that was defective. Training The Administrator will provide training to respirator users and their department heads and/or Supervisors on the contents of this program. The training will include review of their responsibilities and on the OSHA Respiratory protection standard. Employees will be trained prior to using a respirator in their work area. The training session will include the following: The University Respiratory Protection program The OSHA Respiratory Protection Standard Respiratory hazards at the University and their health effects Proper selection of respirators Limitations of respirators Respirator donning and user seal (fit) checks Fit testing Emergency use procedures 10
Maintenance and storage Medical signs and symptoms limiting the effective use of respirators Employees will be re-trained annually, or if they change departments or if new, hazardous materials which need respirator protection, are introduced to the workplace. Employee must demonstrate their understanding of the training topics through hands-on demonstration and a written test. The training will be documented by the Administrator which will include training date, make, model and size of respirator for each involved employee as well as the fit test information for that employee. 5.0 Program Evaluation The Administrator will complete periodic evaluations of the workplace to ensure that the provisions of this program are being effectively implemented. The evaluations will include regular consultations with respirator users, department heads, Supervisors plus air monitoring by a qualified CIH. Program problems will be noted in an inspection log and will be addressed by the Administrator. The findings and problem resolutions, with completion dates, will be provided to management via report by the administrator. 6.0 Documentation and Recordkeeping This program becomes part of the University Injury and Illness Prevention Program (IIPP), but is considered a separate document for monitoring and recordkeeping purposes. Copies of all fit testing and training records are kept in the Administrator offices. Records are updated for all initial and refresher training. Medical records are kept in confidence by the examining physician at the clinic office. Only the physician s recommendations regarding an employee s ability to wear a respirator will be kept by the Administrator. 11