Does the OSHA Federal Regulation 29 CFR 1910.134 – the General Industry Standard for respiratory protection apply to your organization?

Do you know the steps needed to comply with the Occupational Health and Safety Administration (OSHA) respiratory standard requirements?

First, let’s cover whether or not the regulation applies to your organization. According to OSHA:

“Paragraph (a)(1) establishes OSHA’s hierarchy of controls by requiring the use of feasible engineering controls (for example, enclosure or confinement of the operation, general and local ventilation, and substitution of less toxic materials) as the primary means to control air contaminants (dusts, fogs, fumes, mists, gases, smokes, sprays or vapors). Respirators are required when ‘effective engineering controls are not feasible, or while they are being instituted.’'”

“Paragraph (a)(2) requires employers to provide employees with respirators that are ‘applicable and suitable’ for the purpose intended ‘when such equipment is necessary to protect the health of the employee.'”

Have you conducted an exposure assessment?

In order to determine the right equipment, you’ll first need to identify and evaluate the type of respiratory hazards along with estimating employee exposure and identifying what types of airborne contaminants and their levels at the job site. By conducting an exposure assessment, you will understand the types of risks your employees face and can then take a systematic approach to prioritize workplace safety.

  • Tackle the most serious risks first.
  • Control unacceptable exposure levels by developing a plan
  • Keep detailed records for both communicating with the workforce as well as complying with government regulations.
  • Fit testing is required:
    – prior to initial use
    – when a different respirator is used

Following initial fit testing, it should be performed at least annually; it is also recommended for individuals to be fit-tested after significant changes in weight or to facial structure.

What types of fit testing can I do? 

OSHA accepted fit testing can either be Qualitative fit test (QLFT) or Quantitative Fit Test (QNFT).

Do you have a qualified program administrator?

A qualified program administrator is responsible for establishing and implementing a worksite-specific respirator program that has identified procedures for your organization.

A written program is critical to ensuring workplace safety. It is used both internally by workers and management to clearly state responsibilities, is a recordkeeping resource that helps identify past trainings and can be used externally by insurance companies and OSHA compliance officers.

According to the OSHA regulation, what are your responsibilities as an employer?

  • You must provide National Institute for Occupational Safety and Health (NIOSH) certified respirators, training, and medical evaluations at no cost to the employee.
  • Determine that the respirator does not create a hazardous situation
  • Because respirators can put stress on a person’s body, employers must provide medical evaluations deeming whether or not that employee can safely wear a respirator BEFORE fit-testing.
    • Did you know that with different exposures (eg. asbestos), additional medical requirements may be needed including a chest X-ray or pulmonary function test (PFT)?
    • All completed questionnaires must be reviewed by a physician or licensed health care professional (PLHCP) who will provide both the employer and employee with a letter stating whether they are or are not cleared to wear the respirator.
  • Maintain comprehensive records of all exposure assessments
  • Document respirator selection procedures and respirator selection
  • Establish a cartridge change schedule (chemical cartridge respirators)
  • Document training
  • Provide fit testing and maintain records for each employee
  • Develop procedures for inspecting, cleaning, and certifying systems
  • Record evaluations, finding, deficiencies and detail whether any corrective actions are required.

What happens if you are not able to reasonably estimate an employee’s exposure?

OSHA deems that as immediately dangerous to life or health (IDLH). For instance, generally, an oxygen deficient atmosphere is considered an IDLH and that would require a particular type of respiratory protection including a self-contained breathing apparatus (SCBA) or a supplied-air respirator (SAR) that has a self-contained air supply.

What if an employee is not required to wear a respirator, but chooses to do so voluntarily?

The requirements for voluntary respirator use vary depending on the type of respirator worn.  The voluntary use of tight-fitting air purifying respirators requires the same medical evaluation as noted above.  The voluntary use of filtering facepiece respirators (eg. N-95) does not require medical evaluation.  In both scenarios, there is no requirement for fit testing, but employers must provide voluntary users with a copy of Appendix D of the standard (“Information for Employees Using Respirators When Not Required Under the Standard”).

Training & Consulting

Whatever your industry, Arbill is committed to helping your company ensure workplace safety. Our full suite of safety training and consulting options, including site assessments and audits, gap analysis, staff augmentation and industrial hygiene services are provided by highly experienced and certified EHS professionals.


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