UAW-GM Safety System Audit Performance Standard RESPIRATORY PROTECTION Authorized By: Rick O Donnell, UAW Assistant Director Ken Glass, GM Assistant Director Document N Revision 1 Effective Date: May 6, 2016 1.0 Purpose The purpose of this standard is to establish minimum requirements for the identification, evaluation, use and maintenance of respiratory protection equipment in order to drive aggressively towards the elimination of incidents. 2.0 Scope This standard applies to sites that perform tasks that can potentially create respiratory hazards as identified in element 2.0 of the UAW-GM Safety System. These requirements apply to sites outlined in section 3.0 Scope in the General Requirements of the UAW-GM Safety System. This standard does not apply to contractors. Where the nature of the construction or maintenance work requires that contractor employees work in proximity to UAW-GM employees, GM will require, as a condition of the construction or maintenance contract, the contractor s commitment to abide by UAW-GM plant/site Health and Safety work practices. Construction/installation/demolition, service providers, blanket purchase order, spot buy, and production contractors must meet or exceed regulatory requirements and contractual agreements. 3.0 Definitions Action Level: The level of a contaminant at which specified actions or counter measures must be taken. The action level is generally set at 50% of the Occupational Exposure Limit (OEL). 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. Assigned Protection Factor (APF): The workplace level of respiratory protection that a respirator or class of respirators is expected to provide to workers when the employer implements a continuing, effective respiratory protection program. Examples of APFs are found in the OSHA Respiratory Protection Standard. Canister or Cartridge: A container with a filter, sorbent, catalyst, or combination of these items, which removes specific contaminants from the air passed through the container.
UAW-GM Safety System Audit Performance Standard Page 2 of 11 Atmosphere-Supplying Respirators: A respirator that supplies the respirator user with breathing air from a source independent of the ambient atmosphere. They include supplied-air respirators (SARs), airline respirators, and self-contained breathing apparatus (SCBA) units. Emergency Situation: Any occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment, that may or does result in an uncontrolled significant release of an airborne contaminant. End-of-Service-Life Indicator (ESLI): A system that warns the respirator user of the approach of the end of adequate respiratory protection, e.g., he sorbent is approaching saturation or is no longer effective. Filtering Face-piece Respirator: A negative pressure particulate air respirator with a filter as an integral part of the face piece or with the entire face piece composed of the filtering medium (e.g. N, R and P series respirators). This does not include pollen masks (one strap) and surgical masks or any other mask that does not have an assigned protection factor (APF) of at least 10. Fit Factor: A quantitative estimate of the fit of a particular respirator to a specific individual. It typically estimates the ratio of the concentration of a substance in ambient air to its concentration inside the respirator when worn. Fit Test: The use of a protocol to qualitatively or quantitatively evaluate the fit of a respirator on an individual. 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. Maximum Use Concentration (MUC): The maximum atmospheric concentration of a hazardous substance from which a worker can be expected to be protected when wearing a respirator. It is determined by the assigned protection factor (APF) of the respirator or class of respirators and the OEL of the hazardous substance. The MUC can be calculated by multiplying the assigned protection factor specified for a respirator by the OEL. When no OEL is available for a hazardous substance, the RPC must determine a MUC on the basis of relevant available information and informed professional judgment. Negative Pressure Respirator (Tight Fitting): A respirator in which the air pressure inside the face piece is negative during inhalation with respect to the ambient air pressure outside the respirator. Oxygen Deficient Atmosphere: An atmosphere with an oxygen content below 19.5% by volume. Positive Pressure Respirator: A respirator in which the pressure inside the respiratory inlet covering exceeds the ambient air pressure outside the respirator.
UAW-GM Safety System Audit Performance Standard Page 3 of 11 Powered Air-Purifying Respirator (PAPR): An air-purifying respirator that uses a blower to force the ambient air through air-purifying elements to the inlet covering. Pressure Demand Respirator: A positive pressure atmosphere-supplying respirator that admits breathing air to the face piece when the positive pressure is reduced inside the face piece by inhalation. 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. Quantitative Fit Test (QNFT): An assessment of the adequacy of respirator fit by numerically measuring the amount of leakage into the respirator. Self-Contained Breathing Apparatus (SCBA): An atmosphere-supplying respirator for which the breathing air source is designed to be carried by the user. Service Life: The period of time that a respirator, filter or sorbent, or other respiratory equipment provides adequate protection to the wearer. 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. Respirator (Respiratory Protection Equipment, RPE): An approved device (e.g. NIOSH) used to protect the respiratory system from the inhalation of hazardous atmospheres. Respirators provide protection by either removing contaminants from the air before they are inhaled or by supplying an independent source of respirable air. Respirator Program Coordinator (RPC): A site designated person with sufficient knowledge in respiratory protection and overall authority to coordinate all aspects of the program, with assistance as needed. Tight-Fitting Face piece: A respirator inlet covering that forms a complete seal with the face. User Seal Check: An action performed by the respirator user to determine if the respirator is properly seated on their face. 4.0 Requirements 4.1 Planning 4.1.1 Regulatory Compliance
UAW-GM Safety System Audit Performance Standard Page 4 of 11 Each site must identify and comply with all applicable federal and state requirements related to respiratory protection. These requirements must be part of the Regulatory Inventory as described in section 2.1.1 of the UAW-GM Safety System. 4.1.2 Hazard Identification & Risk Assessment Each site must conduct an exposure assessment where potentially hazardous atmospheres exist to identify the hazardous chemicals/processes to which workers may be exposed as described in the Chemical Exposure Assessment Audit Performance Standard (UAW-GM APS 3.4-150), hazard identification and risk assessment processes (section 4.1.2 of the standard). If the monitoring results indicate there is a risk of exceeding the Action Level during normal operations, as well as during hazardous materials emergency response releases, the site must develop and implement a Corrective Action Plan of Controls, following the hierarchy of controls. When effective engineering controls are not feasible, or while they are being instituted, appropriate respirators must be used. The following are the minimum requirements that must be applied when approving use of respirators: The use of PPE is the least effective method of control because its success in protection relies heavily on the practices of the individual wearer. The long-term goal of the respiratory protection program is to eliminate, where possible, the use of respiratory protection. Respirator use is required or mandatory when: There is a potential for overexposure to a contaminant The contaminant exposure is difficult to measure and control due to process variability An oxygen deficient atmosphere or other IDLH atmosphere is present An exposure assessment has not been conducted The RPC determines respirator use is required All activities in which respirators are required to be used must be identified as Tasks and be included on the site s Tasks inventory as described in section 4.1.2 of the Personal Protective Equipment (PPE) Audit Performance Standard (UAW-GM APS 3.4-180). For all Tasks identified, a SOP or standardized work must be developed as described in the Personal Protective Equipment (PPE) Audit Performance Standard (UAW-GM APS 3.4-180) in section 4.1.2. All respirators and respirator accessories (e.g. filters, storage bags, etc.) must be identified as Equipment and included on the site s Equipment Inventory as described in
UAW-GM Safety System Audit Performance Standard Page 5 of 11 section 4.1.2 of the Personal Protective Equipment (PPE) Audit Performance Standard (UAW-GM APS 3.4-180). 4.2 Implementation 4.2.1 Documented Program A Respiratory Protection Program must be developed and implemented for the selection, use, and maintenance of respiratory protection equipment that is used in daily operations and in foreseeable emergency situations. It provides for medical examinations, training, and fit testing of respirator users, as well as establishing a program evaluation means to monitor the effectiveness of the program. The program must address the following, as a minimum: Roles & Responsibilities Hazard identification and risk assessment documentation RPE selection process Medical evaluation for workers who wear respirators User seal checking and fit testing Inspection, maintenance, and storage of RPE RPE wearer training Program evaluation method 4.2.2 Roles & Responsibilities Each site must designate a single qualified person, a Respirator Program Coordinator (RPC), to be ultimately responsible for administering the respiratory protection program. The RPC must have sufficient knowledge in respiratory protection and overall authority to coordinate all aspects of the program. This knowledge may be gained through attendance at an initial Respiratory Protection Course.. They will be assisted as needed by designated personnel. 4.2.3 Respirator Selection The site must follow a systematic process for the selection of RPE and ensure that selection is completed by a qualified RPC. Selected RPE must conform to performance criteria established by NIOSH. RPE will only be specified for use if the elimination of the worker exposure is not feasible, during the installation of engineering controls, and if engineering and administrative controls do not adequately control the exposure to below the applicable occupational exposure limit (OEL). Selection criteria must be based on the following: The nature of the hazard(s) The nature of the task Duration of use
UAW-GM Safety System Audit Performance Standard Page 6 of 11 The capability of the available RPE technology The use of other PPE along with the RPE and the acceptability for use by the wearer. The site must provide RPE capable of minimizing exposures to a level at or below the OELs. Procedures must clearly define the specific RPE requirements, the circumstance(s) when it must be used, and its use limitations. The selection of specialized RPE to support emergency response actions, such as confined space rescue operations, must be reviewed and approved by an occupational safety or industrial hygiene professional. Atmospheric-supplying respirators (i.e. supplied air or SCBAs) must be equipped with pressure-demand regulators. Filtering face-piece respirators must have a filter efficiency that conforms to the NIOSH certification requirements. The selection of RPE must meet the recommended levels of protection required in the applicable chemical-specific standards. Breathing air delivered by approved compressed air or self-contained sources must meet the Grade D air specifications published in the U.S. Compressed Gas Association Standard for breathing air (CGA G-1.1, Commodity Specification for Air, current version). 4.2.4 Medical Evaluation and Surveillance Each site must have a medical evaluation and surveillance process that meets the following minimum requirements: GM Medical Surveillance policy applies to all locations globally. This policy is set by the GM Health Services organization to protect our employees from occupational related injury and illness. At locations where local or state regulatory requirements are more stringent than GM policy, the local or state requirements will be followed. Evaluations are conducted to ensure the use of RPE will not pose any additional hazards to the wearer, as well as ensuring the continued health of the RPE wearer, through the identification of any potential disease outcomes as a result of the program or RPE deficiencies. 4.2.5 User Seal Check and Fit Test Each site must have a user seal check and fit test process that meets the following minimum requirements: Prior to the donning of a negative or positive pressure tight-fitting face piece respirator, the wearer must complete a user seal check to determine if the RPE is properly fitted to their face and in accordance with the manufacturer s instructions. When tight-fitting respiratory protection is required to be worn, each wearer must be fit tested for the respirator prior to use to ensure that the make, model, and size will provide an acceptable face to face-piece fit. The fit test method used and
UAW-GM Safety System Audit Performance Standard Page 7 of 11 the periodic update (e.g. annually) must follow either the federal, state or local regulatory requirements, or the manufacturer s recommendation, whichever is more stringent. When respiratory protection is required, tight-fitting respirators may not be used when conditions prevent a proper seal of the RPE to the wearer or cause interference with the valves. Such conditions include: facial hair that comes between the sealing surface of the face-piece and face or that interferes with valve function; any spectacle with temple bars or straps; and a head covering, goggles, face shield, welding helmet, or other PPE device which pass between the sealing surface of the RPE and the wearer s face. In addition, the following requirements must apply: The site s position on tight-fitting respirator use with facial hair must be clearly defined and include when facial hair is and is not acceptable. Facial features which prevent a good seal of the RPE tight-fitting facepiece to a wearer s face may disqualify the person from wearing a respirator. Personnel that conduct fit testing must be evaluated annually and retrained if necessary. This training must be provided by the fit test system manufacturing representative or personnel trained by the representatives. 4.2.6 Equipment Inspection, Maintenance, and Storage Each site must implement a process for the inspection, maintenance, and storage for all respiratory equipment (e.g. respirators and respirator accessories) identified in section 4.1.2 of this standard, that meets the following minimum requirements: Prior to each use, respirators must be inspected according to the manufacturer s instructions or federal/state/local regulatory requirements, whichever is more stringent. In order to be maintained in a sanitary condition, each respirator should be washed according to the manufacturer s instructions. Repairs to respirators may only be performed by qualified personnel using only replacement parts approved by the manufacturer. Respirators must be stored when not in use in a manner that protects them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals, as well as to prevent any deformities of the face-piece and valves. The original respirator storage bags may be used for this purpose. 4.2.7 Respirator Change Schedule Each site must implement a respirator change schedule process that meets the following minimum requirements: An air purifying respirator must be equipped with a certified (e.g. NIOSH) end-ofservice-life indicator (ESLI) for the contaminant. If there is no ESLI appropriate for conditions in the site, a change schedule must be implemented for canisters and cartridges that is based on objective
UAW-GM Safety System Audit Performance Standard Page 8 of 11 information or data that will ensure that canisters and cartridges are changed before the end of their service life. The change schedule should be posted in the affected areas. The respirator wearer is responsible to determine when to change their filters and cartridges. A description of the information and data relied upon, the basis for the canister and cartridge change schedule, and the basis for reliance on the data must be included in the respirator program. 4.2.8 Voluntary Use of Respirators When air sampling demonstrates the potential for overexposure as compared to the action level or an oxygen deficiency is unlikely, use of respirators is considered voluntary. To use voluntary respirators, the following conditions must be met: A respirator medical evaluation has determined the worker is physically capable of wearing a respirator. This includes filtering face piece respirators. Training must be conducted for the voluntary use of elastomeric face-piece respirators or PAPRs (e.g. half- or full face-piece filter or cartridge air purifying respirators or supplied air respirators). Note: No fit testing is required with filtering face piece respirators. Appendix D of the OSHA Respiratory Protection Standard must be provided to all Voluntary Users of Respiratory Protection, including those who wear filtering face-piece respirators. Note: if employees are not required to wear a respirator, and voluntarily choose instead to purchase and wear a mask for comfort that does not have an applied protection factor (APF) of at least 10, (e.g. pollen mask, surgical mask), then there is no requirement for a medical evaluation, training, fit testing or providing Appendix D from the OSHA Respiratory Protection Standard as these are not considered filtering face piece respirators. 4.2.9 Training Each site must have a documented training program for respirators that meets the following minimum requirements: The Respirator Program Coordinator (RPC) must ensure that respirator wearers receive appropriate training on the proper and safe use of respirators. The RPC must establish and implement more frequent training requirements for workers who use more complex RPE types, such as self-contained breathing apparatus (SCBA) and powered-air purifying respirators (PAPR). Annual training must address the following: The potential and actual hazards for which respiratory protection may be used The adverse effects of exposure if the respirator is not properly used, including signs and symptoms of exposure Tasks and areas for which respiratory protection use is required
UAW-GM Safety System Audit Performance Standard Page 9 of 11 Why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator What the limitations and capabilities of the respirator are, including the replacement requirements for filters and cartridges How to put on (don) and remove (doff), use, and conduct the user seal checks and fit test of the respirator How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions, and the use of emergency escape devices, including limited use SCBAs and mouthpiece devices How to inspect, maintain, and store respirators How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators Site specific work rules, such as facial hair policies Specialized training for workers who wear air-supplying respirators, including SCBAs and airline respirators 4.2.10 Emergency Response Each site must include in the emergency response process the following minimum respirator related requirements: Each site must identify and address specialized training needs for emergency response situations which involve the use of emergency RPE. SCBA wearers must receive specific training and demonstrate proficiency through planned drills, in accordance with the site s emergency response plan. A frequency of initial and refresher training must be established to meet proficiency and federal/state/local regulatory requirements. Sites that use SCBA equipment for emergency response must complete a documented needs assessment that includes the minimum number of supplied air systems required. 4.2.11 Documentation Documents and records related to respirators must be included in the site s document control program as outlined in section 3.3 of the UAW-GM Safety System, and retained in accordance with ILM requirements. At a minimum, these include the following: Hazard identification and risk assessment documentation A log of all required use and voluntary respirators issued Worker training records Planned inspection documentation Program evaluation documentation 4.2.12 Management of Change The site must have a documented process to identify, and control all new respiratory protection related hazards associated with people, equipment, or process changes,
UAW-GM Safety System Audit Performance Standard Page 10 of 11 which is consistent with requirements outlined in the Management of Change Audit Performance Standard 3.5-010. Hazard Identification Inventories and Risk Assessments outlined in section 4.1.2 of this standard must be updated to reflect any changes. 5.0 Checking and Corrective Action 5.1 Planned Inspection The site Planned Inspection Program must include Task observations and Equipment inspections associated with respirator use in order to monitor whether the rules and procedures are being followed. 5.2 Program Evaluation The Respirator Program Coordinator (RPC) must conduct an annual program review to evaluate implementation effectiveness. At a minimum, this review must include the following: Investigation of reports of hazardous atmospheric exposure incidents, including nearmisses and fatalities Related corrective and preventative actions to ensure timely completion and evaluation trends Fit testing records Inspection, maintenance, and storage of respirators Planned inspection records and employee feedback Work procedures which specify the use of RPE Training effectiveness Assessment of the program against the long-term objective of eliminating the need to wear RPE The results of this program evaluation must be reviewed during the Leadership Review process as outlined in section 5.0 of the UAW-GM Safety System. 6.0 Related Documents 2.4-180 Personal Protective Equipment Performance Standard OSHA Standard 29 CFR 1910.134 Respiratory Protection UAW-GM SS GD 2.4-180 Respiratory Protection
UAW-GM Safety System Audit Performance Standard Page 11 of 11 Revision History Date Rev # Change Made Author(s) 8/17/2015 0 Initial Version based off GMS & Revisions of Purpose E. Bolden and Scope; added definition & references to the term Action Level 3/29/2016 1 UAW-GM version, first version. B. Chapman T. Cobb