Respiratory Protection Plan

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    Introduction

    The Respiratory Protection Plan is designed to help the St Cloud School District comply with the Occupational Safety and Health Administration's (OSHA) Respiratory Protection standard (29 CFR 1910.134). This Plan outlines standard operating procedures for the use of respirators to protect the St Cloud School District employees from harmful or hazardous exposures by way of inhalation. A reference compliance checklist can be found in Appendix A.

    This Plan is intended to be non-site-specific and will need to be modified to adapt to specific conditions at each site or school district. In addition, the St Cloud School District is responsible for the implementation, enforcement and updating of their Respiratory Protection Plan. It is recommended that the Plan be reviewed and updated annually or as hazardous conditions and operations change. Actual use of this Plan is limited to Resource Training & Solutions and the St Cloud School District which it represents.

     

    Plan Review and Updated Report

    Respirator Management Plan Review & Update Report

    Program review and changes are documented below. Documented reviews indicate that the plan continues to meet the needs of the District, or has been modified to do so more effectively.

     

     Date  Updates/Notes  Reviewer
     5/27/16 Updated employee respirator inventory  Wayne Warzecha
     6/2/16 Updated employee respirator inventory

    Updated emergency contact numbers 

    Added Appendix G: respirator change-out schedule

    Added appendix H: Voluntary respirator use statement and record.

    Added filter replace information under respirator selection section: Air-Purifying

    Added Appendix I: medical questionnaire evaluation

     Wayne Warzecha
         
         
         
         
         


      
    Overview

    The St Cloud School District shall reduce the level of air contaminants to the lowest level possible through engineering and/or administrative control measures. Where this is not possible or such control measures are in the process of being implemented, the St Cloud School District shall provide the appropriate level of respiratory protection (respirators) at no cost to the employee. In most cases, where employee exposures exceed applicable OSHA permissible exposure limits or other appropriate standards or guidelines, respirators are worn to reduce the employee's exposure to a level below the relevant standard.

    Where respirators are used, OSHA requires written standard procedures as outlined in 29 CFR 1910.134. A copy of the OSHA Respiratory Protection Standard can be found in Appendix D (refer to Master Regulations Manual).

     

    Hazard Analysis

    Job/Work-Task Classifications

    The St Cloud School District shall conduct an inventory of their operations to identify hazardous conditions relative to job classifications/work tasks. A majority of the potential chemical exposures should be available from the hazardous substances inventory (refer to the school district's Employee Right-to-Know Plan). Typical operations or work activities where chemical exposures may exist include, but are not limited to, the following:

    • Science Chemicals        
    • Pool Chemicals       
    • Repair work or cleaning in confined spaces (refer to St Cloud School District's Confined Space Entry Plan)
    • Pesticide spraying (buildings and grounds)
    • Painting
    • Welding
    • Repair or cleanup of asbestos-containing materials
    • Boiler cleaning
    • Chemical spill cleanup (refer to St Cloud School District's Hazardous Waste Management Plan)

    Exposure Assessment

    The St Cloud School District shall determine the exposure level for each contaminant identified in the Job/Work-Task inventory. Contaminants can be in any one, or combination of, chemical or physical states:

    • Dusts/Fibers
    • Mists (aerosols)
    • Fumes
    • Gases
    • Vapors
    • Liquids (solids)
    • Smokes

    Where practical, employee exposures to hazardous substances present should be evaluated to determine the average concentration over the entire work day or actual time period for the operation/work-task in question. In addition, the ceiling concentration or peak exposure level should also be determined. Exposure estimates may rely on personal or representative data, professional judgment, or exposure modeling.

    The St Cloud School District shall also identify any oxygen deficient environments (conditions where the oxygen level is less than 19.5%) within confined spaces.

    In situations where the employee-exposures exceed applicable OSHA exposure limits or other relevant standards, the school district shall implement engineering and/or administrative controls to reduce the exposure level. Where the employee exposure level cannot be reduced below the permissible level or during actual implementation of the engineering or administrative controls, the St Cloud School District shall provide employees with the appropriate respirator to reduce exposures to below the permissible level.

    If the St Cloud School District cannot identify or reasonably estimate a school employee's exposure, the school district shall consider the atmosphere to be IDLH.

     

    Respirator Selection

    Selection Factors

    Several factors come into play when selecting an appropriate respirator. These may include the following:

    • The nature and properties of the hazard (e.g. toxicity, dust versus vapor).
    • The extent or degree of hazard present.
      • airborne concentration
      • duration (length) of exposure
      • effectiveness of engineering controls
    • The permissible exposure limit (PEL) or threshold limit value (TLV).
    • Oxygen-deficient environment.
    • Adequate warning properties of hazardous substance (i.e. odor, taste, irritation).
    • Work or job task requirements and conditions.
    • Overall health and ability of worker to wear a respirator.
    • Comfort and maintenance requirements of respirator.
    • Need for maintaining communication while wearing a respirator.
    • The protection factor afforded by the respirator.
    • Interferences with specific types of respirators with work tasks.

    In all cases, the St Cloud School District will provide approved or accepted respirators when required to be worn by employees. Respirators are approved by the National Institute for Occupational Safety and Health (NIOSH). Each respirator is approved as an overall system and will be identifiable with the following label on the respirator.

    NIOSH
    Approval No. TC-XXX-XXX

    Note: The XXX are specific for each type of respirator

    A compilation of approved respirators is available in the NIOSH Certified Equipment List reference manual. Actual Respirator Performance Requirements are outlined in Title 42 CFR Part 84.

    The St Cloud School District shall select respirators from a sufficient number of respirator models and sizes so that the respirator is acceptable to, and correctly fits the user.

    Respirator Types

    There are two primary categories of respirators: air-purifying and air-supplying.

    1. Air-Purifying Respirators

      Air-purifying respirators have filters or cartridges which act to remove contaminants from inhaled surrounding air. There are six primary styles of air-purifying respirators:
      • filtering face piece (dust mask)
      • tight-fitting, half-face (covers nose and mouth)
      • tight-fitting, full-face (covers entire face and has a see-through lens cover)
      • tight-fitting gas masks
      • powered air-purifying respirators (PAPR) (tight-fitting or loose-fitting hood/helmet)

    They can be used to protect against dust, fumes and mists when used with particulate filters. Particulate filters can be used for all substances that have a threshold limit value (TLV) equal or greater than 0.05 milligrams per cubic meter (mg/m3). High efficiency particulate absolute (HEPA) filters should be used to protect against any substances with a threshold limit value less than 0.05 milligrams per cubic meter. All work associated with potential asbestos exposures requires a high efficiency particulate absolute filter. These type of filters are 99.97% efficient against particles down to 0.3 microns in size.

    Chemical cartridges or canisters (gas masks) are available for a variety of vapors and gases. These cartridges or canisters act to adsorb or absorb the chemical contaminants during inhalation.

    There are combination air-purifying respirators, filters and cartridges, available to protect against both particulates and vapors/gases at the same time (for example, paint mists and vapors during a paint operation). There is also a Universal or Type "N" gas mask canister which provides protection against a wide variety of contaminants.

    The Powered Air-Purifying Respirator ("PAPR") has a battery-powered blower that acts to pull air through the filter and/or chemical cartridge and then distributes the "cleansed" air to the face mask. The blower supplies air at a positive pressure to the face mask. As a rule of thumb, these respirators are required to provide a minimum of 4 cubic feet of air per minute for a tight-fitting face mask and a minimum of 6 cubic feet of air per minute for a loose-fitting hood or helmet style respirator.

    In general, filters, chemical cartridges and gas canisters are color-coded relative to the type of contaminant or substance. For example, organic vapor cartridges are black, high efficiency particulate absolute filters are purple, acid gases are white, and so on. A breakdown of color codes can be found in the American National Standards Institute K13.1: however, the school district employees should verify specific filter or cartridge applications by always reading the information on the label.

    The St Cloud School District shall ensure that all filters, cartridges and canisters used by school employees are labeled and color-coded with the NIOSH-approved label and that the label is not removed and remains legible.

    Air-purifying respirators are never to be used in oxygen deficient environments (oxygen content less than 19.5%). In addition, they should not be used in environments which present an immediate threat to life or health or an exposure to contaminants likely to have delayed adverse health effects. These types of environments are commonly referred to as Immediately Dangerous to Life and Health or IDLH. The St Cloud School District will identify any substances present which have an established IDLH level.

    2. Atmosphere-Supplying Respirators

    Atmosphere-supplying respirators provide air to the respirator from a source other than the surrounding air. There are two primary types of air-supplying respirators:

      • Airline Respirators, and
      • Self-Contained Breathing Apparatus (SCBA)

    Airline respirators rely on a blower (also referred to as Type "A") or compressor system (also referred to as Type "C") providing air through an air hose directly to the respirator. The respirator itself is either a half-face, full-face, hood or helmet. There are three types of Type "C" respirator systems:

      • Continuous air flow — supplies continuous air to respirator.
      • Demand air flow — supplies air to respirator only during inhalation.
      • Pressure demand air flow — maintains positive pressure inside respirator.

    The St Cloud School District will implement the following practices in operations where Type "C" respiratory protection is used.

      • The length of airline hose shall never exceed 300 feet.
      • A pressure reducer valve shall be used to restrict the pressure at the airline — air supply source to a maximum inlet pressure of 125 pounds per square-inch gauge (psig).
      • The compressor shall provide a minimum of 4 cubic feet of air per minute to a tight fitting respirator mask or a minimum of 6 cubic feet of air per minute for a loose fitting hood or helmet.
      • The air compressor (or blower system if applicable) should be located in an area where contaminants are minimal.
      • The compressor system shall provide Grade D air as a minimum (carbon monoxide less than 20 parts per million, carbon dioxide less than 1,000 parts per million and condensed hydrocarbons less than 5 milligrams per cubic meter).
      • Pure oxygen shall never be used. Airline couplings shall be incompatible with outlets for other gas systems to prevent inadvertent gases used with the airline respirator.
      • The compressor system shall include the following:
        • a series of in-line traps and filters to remove oil, water and other contaminants from the incoming air supply;
        • a high temperature or carbon monoxide alarm if a oil lubricated compressor is used;
        • an alarm for indicating compressor failure or shutdown; and
        • an auxiliary or back-up air cylinder source to accommodate air compressor shutdowns.

    Note: As a precautionary measure, it is advisable to have a back-up filter or cartridge (depending on contaminant[s] present) in-line. Should the entire system fail, the user could still exit the site under the equivalent of a full-face air purifying respirator.

    Self-contained breathing apparatus (commonly referred to as SCBA) supply air from a cylinder or tank carried by the user in the form of a backpack. The SCBA consists of a face piece, tube assembly, regulator, compressed air cylinder and a back harness. There are three types of SCBA respirators.

      1. Demand or pressure demand open circuit system.
      2. Self-generating (re-breathing) closed circuit device.
      3. Liquid or compressed oxygen closed circuit device.

    Note: Compressed oxygen shall not be used in a open circuit SCBA which previously used compressed air.

    Open circuit SCBAs usually provide up to 30 minutes of service life. Closed circuit SCBAs provide between one to four hours of service life depending on the actual style. Consequently, closed circuit SCBAs are more practical for long operations (i.e., beyond 30 minutes in length).

    Protection Factors

    The protection factor for a respirator is the ratio of the contaminant concentration outside of the respirator to the contaminant concentration inside the respirator. Each type of respirator has an assigned protection factor from the manufacturer. In general, the following protection factors have been assigned to the respirator types specified.

    Protection Factors

    The protection factors assigned assume that a good face-to-respirator fit is obtained. The protection factor of a respirator determines the maximum use concentration an employee can safely work under. The maximum use concentration for any type of respirator is determined by the following equation:

    MUC = PF x PEL

    MUC - maximum use concentration for a specific contaminant.
    PF = Protection factor afforded by the respirator.
    PEL = permissible exposure limit (or threshold limit value) for the contaminant.

    Note: The St Cloud School District should always verify the protection factor for each type of respirator from the manufacturer.

    When determining the MUC, the MUC cannot exceed 10 percent of the LEL or the IDLH concentrations for the contaminant(s).

    As an example, a worker wearing a fitted half-face respirator with high efficiency particulate absolute (HEPA) filters can safely work at asbestos concentrations up to 2 fibers per cubic centimeter of air.

    MUC = 10 x 0.2 fibers per cubic centimeter of air
    = 2 fibers per cubic centimeter of air

    Limitations

    In selecting the appropriate respirator relative to the contaminants(s) present, and the levels school employees are exposed to, it is imperative to have an understanding of the limitations associated with each type of respirator.

    Air-Purifying — The half- and full-face air-purifying respirators are considered negative pressure respirators. When a user inhales, a slight negative pressure exists inside the respirator mask. If a good face-to-respirator seal does not exist, any leakage will result in contaminants being drawn inside the mask during inhalation. Likewise, the protection is reduced. This is one of the benefits of a powered air-purifying respirator. Since air is continuously being distributed to the face mask, the negative air pressure during inhalation is minimized or in some cases, eliminated.

    The air-purifying respirators as a class have lower protection factors in comparison to the air-supplied class of respirators. Consequently, the maximum use concentrations are lower. Air-purifying respirators cannot be used in oxygen deficient environments or in high concentrations of contaminants immediately dangerous to life and health (IDLH). Use of air-purifying respirators are also limited to contaminants which have adequate warning properties (odor, taste, irritation). For example, methylene chloride is odorless and exposure to hydrogen sulfide can produce olfactory fatigue, whereby the ability to smell is diminished over time. As a general rule of practice, the St Cloud School District should always verify with the respirator manufacturer which type of filter, cartridge or combinations are required for the contaminants of concern.

    When using a Type "N" or universal canister with a gas mask to protect a worker from carbon monoxide, an indicator window should be present to visual evaluate the remaining carbon monoxide catalyst available. The worker should also be aware that the breathing air may become hot at higher carbon monoxide concentrations as a result of the chemical interaction with the catalyst material.

    The powered air-purifying respirator system relies on a battery-powered blower system. Periodic recharging of the battery is required to maintain the required air volume delivered to the face mask. On occasion, loss of power may result. Should this occur the worker is still protected; however, the protection factor is reduced to the equivalent of a half- or full-face negative pressure air-purifying respirator depending on which type of face mask is on at the time.

    If working with contaminants that are known eye or skin irritants, a full-face respirator should be used.

    Filter service life is limited. With particulate filters, as the filter becomes loaded, resistance to airflow increases and breathing requires more effort. With chemical cartridges, the service life is limited, replace filters:

    • When the expiry date stamped on the sealed packet has elapsed.
    • Once, opened, maximum use time is 6 months (even if not used). The carbon will absorb contaminants from the general environment.
    • When contaminant can be detected by smell or taste.
    • Or in accordance with your established filter change schedule. A schedule can be found at Appendix H.

    Several different sizes and brands of air-purifying respirators may be required to obtain an adequate and comfortable fit for all employees.

    Working under hot temperature conditions may result in added stress to a worker wearing an air-purifying respirator. In addition, excessive perspiration may affect the face-to-respirator seal.

    Under extreme cold weather conditions, fogging of the lens may occur with a full-face respirator. To minimize fogging, the inner lens shield can be coated with an anti-fogging product. Full-face respirators are also available with a nose/mouth cup inside the mask which aids in directing the warm, moist exhaled air out of the mask. Under very low temperature conditions, the possibility of the exhalation valve freezing also exists.

    Air-Supplied — In general, the air-supplying class of respirators provide a higher level of protection and minimize the amount of breathing resistance experienced by the user. One of the primary drawbacks with this class is that they tend to be a bulkier, heavier system to wear.

    The airline or Type "C" respirator requires a minimum of Grade D breathing air be delivered to the respirator at all times. Some of the more common limitations with this type of system include:

    • Compressor system shutdown or failure requiring a back-up auxiliary system, filter/ cartridge attachment to the respirator, or an escape bottle.
    • Maintenance and on-going inspection of the filters and traps to ensure Grade D breathing air.
    • Maximum limit of 300 feet of airline hose limiting the distance of the working zone.
    • Additional safety hazards with the airline hoses becoming entangled with other airline hoses or objects within the work area; increased likelihood of trips and falls over the airline hoses.

    The SCBA type respirators generally are much bulkier and heavier adding more strain to the worker. In addition, the backpack may limit work access in and around tight or constricted areas. One of the primary limitations with SCBA respirators is that they have limited service life and require frequent recharging of the air cylinders.

    Emergencies

    There are three primary types of emergency situations where respiratory protection may be required.

    1. An employee's self-rescue during a chemical spill or leak.
    2. Rescue of personnel trapped or overcome in a hazardous environment.
    3. During shutdown or repair of an operation creating a hazardous environment or where a potential for the sudden and rapid release of contaminants exists.

    In general, if a worker could be overcome by toxic contaminants while wearing a respirator, at least one other standby worker should be present maintaining communication at all times. In situations where a worker is in a oxygen deficient or immediately dangerous to life and health environment, a standby person is required.

    Workers wearing an air-purifying respirator in an area where an emergency occurs should .exit the area immediately. Depending on the level of hazard for each operation, the availability of an air-purifying respirator may be made available for escape purposes.

    A pressure demand SCBA or airline Type "C" with an auxiliary air tank is required in all emergency situations where an oxygen deficient or immediately dangerous to life and health environment exists. It is important to keep in mind the service life of the system used during escape or rescue situations. Workers within these types of environments should be equipped with safety harnesses or safety lines for rescue-removal purposes when in confined spaces. In addition, a pressure demand SCBA should be available outside the hazardous environment should an outside standby person need to enter the area for rescue purposes.

     

    Fit test

    Step 1: Medical Evaluation Questionnaire:

    This questionnaire must be completed by every employee who has been selected to use any type of respirator. There are two options to obtain medical clearance for wearing a respirator.

    • Option 1: Refer to Appendix D of this written plan for the OSHA Standard 1910.134 Appendix C. Complete OSHA’s Appendix C of section 1910.134 Standard: (mandatory) OSHA Respirator Medical Evaluation Questionnaire. Part A. Section 1 and Section 2 questions 1 through 9 must be answered by every employee who has been selected to use any type of respirator. Questions 10 to 15 must be answered by every employee who has been selected to use either a full-face piece respirator or a self-contained breathing apparatus (SCBA). For employees who have been selected to use other types of respirators, answering these questions is voluntary. The questionnaire can be reviewed by the School Nurse or local Physician and determine whether or not a follow-up exam is needed.
    • Option 2: Alternatively an on-line respiratory questionnaire is available from the 3M Company. At this website www.respexam.com. The on-line version should take approximately 15 to 30 minutes. It is reported that 90% of those completing the questionnaire/exam will be able to print out a clearance letter, which is to be retained for OSHA recordkeeping. The cost is $25.00.


    Step 2: Fit-Testing (tight fitting respirator only)

    Before an employee may be required to use any respirator with a negative or positive pressure tight fitting face piece, the employee must be fit-tested with the exact respirator they will be using and at least annually thereafter. NOTE: Fit-testing is not required for loose fitting PAPRs.

    Fit testing options:

    a.     Purchase a Saccharin, Britex or similar brand name fit test kit and do yourself or;
    b.     Arrange for outside firm to perform fit testing

    Step 3: Fit Check/Seal Check: (tight fitting respirators only)

    Appendix B-1 to §1910.134: User Seal Check Procedures (Mandatory)
    (This every time worn seal check procedure is commonly referred to as a “fit check” as opposed to annual fit testing)
    The individual who uses a tight-fitting respirator is to perform a user seal check to ensure that an adequate seal is achieved each time the respirator is put on. Either the positive and negative pressure checks listed in this appendix, or the respirator manufacturers user seal check method shall be used. Every time worn user seal checks are not substitutes for annual fit tests.

    How to perform every time worn Facepiece Positive and/or Negative Pressure Checks

    1. Positive pressure check. Close off the exhalation valve and exhale gently into the facepiece. The face fit is considered satisfactory if a slight positive pressure can be built up inside the facepiece by blowing into the respirator without any evidence of outward leakage of air at the seal.
    2. Negative pressure check. Close off the inlet opening of the canister or cartridge(s) by covering with the palm of the hand(s), inhale gently so that the facepiece collapses slightly, and hold the breath for ten seconds. The design of the inlet opening of some cartridges cannot be effectively covered with the palm of the hand. The test can be performed by covering the inlet opening of the cartridge with a thin latex or nitrile glove. If the facepiece remains in its slightly collapsed condition and no inward leakage of air is detected, the tightness of the respirator is considered satisfactory.

      II. Manufacturer’s Recommended User Seal Check Procedures
      The respirator manufacturer’s recommended procedures for performing a user seal check may be used instead of the positive and/or negative pressure check procedures provided that the employer demonstrates that the manufacturer’s procedures are equally effective. [63 FR 1152, Jan. 8, 1998]


    Powered Air Purifying Respirators (“PAPR’s”):

    All PAPR wearers need to comply with “step 1” options 1 or 2. Loose fitting PAPR wearers need not to comply with steps 2 or 3, while tight fitting PAPR wearers need to comply with steps 2 and 3.

     

    Maintenance Program

    Inspection

    All respirators should be routinely inspected before each use and during cleaning. Emergency use respirators shall be inspected before and after each use and on a monthly basis if frequency of use each month is minimal. Inspection of emergency use respirators shall be tagged or recorded as an indication to workers that they are ready for use. All SCBA respirators shall be inspected monthly (as a minimum).

    General inspection procedures are as follows:

    • Air-Purifying Respirators
    • Check the tightness and fit of all connections. 
    • Examine harness and head straps for elasticity or breaks. 
    • Evaluate face piece snaps and buckles. 
    • Evaluate the rubber or elastomer parts for pliability and any signs of deterioration or distortion. 
    • Examine overall cleanliness and any signs of dirt.
    • Examine inhalation and exhalation valves for signs of foreign debris, valve seat, deterioration or warping. 
    • If a hood or helmet style, examine the integrity of all seams.
    • Examine face shield lens (full-face respirator) for excessive scratches which may impair vision. 
    • Examine filters, cartridges or canisters for dents, corrosion, incorrect types, proper installation, integrity of gaskets and expired shelf life. 
    • Inspect the breathing tube assembly on powered air-purifying units for cracks or deterioration. Inspect the blower unit and battery pack for proper operation.

    Air-Supplied Respirators

    • Inspect the respirator face mask for pliability, signs of distortion or deterioration, and excessive scratches on the face shield lens (full-face respirator).
    • Inspect the airline hose and regulators for overall integrity and tight fitting connections. 
    • Inspect the compressor and filtration system as per manufacturer's recommendations. 
    • Inspect the regulator, fittings, gauges and warning devices on the SCBA. 
    • Recharge air cylinders if less than 100% of useful service time remains. Never use pure oxygen (presence of dirt or grease could result in an explosion). 
    • Inspect the closed circuit canister for remaining life.

    When repairing or replacing respirator parts, only manufacturer certified parts should be used. Never interchange parts made for another style or brand of respirator. The NIOSH approval will become invalid if non-approved parts are used.

    Cleaning

    The St Cloud School District will assign individuals their own respirator with a unique identification number where practical. All respirators should be properly cleaned after each use and disinfected as necessary (after each use if shared with other individuals) according to manufacturer's recommendations.

    General cleaning procedures for respirator face masks are as follows:

    • Remove all straps (where possible), speaking diaphragms, filters, cartridges or canisters. Wash all remaining rubber or elastomer parts in warm water. Water temperature should not exceed 110°F. Rinse well with clean, warm water.
    • Respirator face masks can be disinfected by one of three methods: 
      • Wipe down with a disinfectant wipe available from the manufacturer. 
      • Immerse mask for two minutes in a 50 parts per million chlorine solution. This can be made using any household bleach by adding 2 milliliters bleach (or two tablespoons) to 1 liter (or one gallon) water. 
      • Immerse mask for two minutes in a aqueous solution of iodine (add 0.8 milliliters tincture of iodine to 1 liter of water).

        Note: Some respirator manufacturers also provide disinfectants in the form of sprays or tablets which are dissolved in water.
    • Respirators should be thoroughly rinsed with clean, warm water (110°F maximum) to remove any remaining disinfectant which may irritate the facial skin or potentially age the rubber or rust the metal parts. 
    • Respirators should air dry or be manually dried with a lint-free cloth. 
    • Carefully wipe all other parts removed with a damp lint-fee cloth. 
    • Reassembly respirator and verify that all parts are in place. Thoroughly inspect entire respirator before placing in storage. 
    • Prior to re-use, test the respirator to ensure that all components work properly.

    Storage

    All respirators and filters, cartridges and canisters should be stored in a clean, sealable container or bag. Respirator storage should provide protection from temperature extremes, dust, sunlight, excessive moisture, chemicals or mechanical damage. In addition, respirators should be stored so that the face piece will rest in its normal position to avoid distortion of the shape. Respirators should not be hung by their straps for storage purposes.

    Emergency use respirators must be located in a readily accessible storage area.

    Store defective respirators separately from useable respirators.

     

    Program Surveillance

    The St Cloud School District shall designate a program administrator. The administrator shall be qualified by appropriate training or experience that is commensurate with the complexity of the program. The administrator should conduct random inspections to evaluate proper respirator practices are being used and to evaluate the overall effectiveness of the program.

    This includes periodic review of hazards present, exposure data (air concentrations), engineering or administrative controls in place, changes in processes or equipment, any job function impairments while wearing a respirator, and discuss with employees any other issues associated with respirator use. Additionally, changes in process, equipment, or chemical use needs to be reviewed prior to implementation and changes to the program need to be addressed.

     

    Medical Surveillance Program

    All workers who are required to wear a respirator must be physically fit to wear a respirator and safely perform their respective work tasks. The St Cloud School District will provide all respirator wearers a medical exam by a physician or other licensed health care professional (PLHCP) at no cost to the employee. Medical exams will be provided prior to initial use of any assigned respirator and annually thereafter or more frequently if directed by the PLHCP.

    The St Cloud School District shall also provide additional medical evaluations if an employee reports signs or symptoms of exposure, changes in the ability to use a respirator, or a change occurs in the workplace condition that may result in a substantial increase in the physiological burden placed on the employee.

    The following information must be provided to the PLHCP before the PLHCP makes a recommendation concerning the employee's ability to use a respirator.

    • The type of the respirator to be used by the employee. 
    • The duration and frequency of respirator use. 
    • The expected physical work effort. 
    • Additional protective clothing and equipment to be worn. 
    • Temperature that may be encountered. 
    • Nature of exposure (contaminant, concentration).

    The St Cloud School District shall provide the PLHCP with a copy of the written Respiratory Protection Program and the Respiratory Protection Standard.

    The medical exam should include a work history review (questionnaire), evaluation to identify any physical or psychological limitations, pulmonary function test and a chest x-ray. The St Cloud School District should also identify those hazardous substances present which have their own OSHA standard specifying additional medical surveillance requirements. For example, there are OSHA standards with medical surveillance requirements for asbestos and lead.

    In determining the employees ability to use a respirator, the St Cloud School District shall obtain a written recommendation regarding the employee's ability to use the respirator from the PLHCP. The recommendation shall provide only the following information.

    • Any limitations on respirator use related to the medical condition of the employee, or relating to the workplace conditions in which the respirator will be used, including whether or not the employee is medically able to use the respirator. 
    • The need, if any, for follow-up medical evaluations. 
    • A statement that the PLHCP has provided the employee with a copy of the PLHCP's written recommendation.

    If the respirator is a negative pressure respirator and the PLHCP finds a medical condition that may place the employee's health at increased risk if the respirator is used, the St Cloud School District shall provide a PAPR if the PLHCP's medical evaluation finds the employee can use such a respirator.

     

    Training Program

    All St Cloud School District employees required to wear respirators shall receive training prior to initial use and annually thereafter. The primary components of the training program include the following:

    • General requirements of 29 CFR 1910.134 (Respiratory Protection).
    • Job classifications and work-task activities which require use of a specific type of respirator. 
    • Nature of the hazards and why a respirator is needed and how improper fit, usage or maintenance can compromise the protective effectiveness of the respirator. 
    • Proper respirator selection and their limitations.
    • Fit-test procedures. 
    • Inspection, donning, doffing, and checking the seals of the respirator. 
    • Maintenance, cleaning and storage procedures. 
    • How to recognize medical signs and symptoms that may limit the effective use of respirators. 
    • Overview of special environments such as confined spaces and IDLH. 
    • Emergency use procedures, including situations in which the respirator malfunctions.
    • Hands-on training allowing time to adjust and perform fit test checks.

    The training shall be conducted in a manner that is understandable to the employee. In addition, the St Cloud School District shall ensure that each employee can demonstrate knowledge of the above-referenced information.

    A Respiratory Protection Training Log can be found in Appendix B.

     

    Recordkeeping

    The St Cloud School District should retain the following records associated with their Respiratory Protection Program.

    A. Hazard Analysis

      • Records of all operations, job classifications and work-task activities requiring a respirator.
      • Employee exposure monitoring records shall be retained by the school district for at least 30 years.

    B. Fit Tests

      • Records of individually assigned respirators.
      • Emergency use respirators inspection records.
      • Fit test records (qualitative and quantitative if applicable)
      • Fit test records shall be retained for three years (minimum).

    C. Training

      • Record of the training program topics and a log of attendance.
      • Training records shall be retained for three years (minimum).

    D. Medical

      • Individual employee medical records shall be retained for the length of employment plus 30 years.

     

    Appendix A: Compliance Checklist

    The following checklist is intended to provide a quick reference for an individual school district to evaluate their level of compliance with OSHA's Respiratory Protection Standard (29 CFR 1910.134).

    • Program administrator designated. 
    • Hazardous employee exposures identified and evaluated. 
    • Respirator types have been selected. 
    • Employees have undergone medical exams. 
    • Employees have received training. 
    • Respirator fit tests performed. 
    • Recordkeeping system in place.

    Note: This checklist is not intended to be comprehensive in nature. Each school district should refer to their respective Respiratory Protection Plan which further outlines general compliance requirements.

     

    Appendix B: Training Log

     

    Appendix C: Qualitative Respirator Fit-Test Record

     

    Appendix D: OSHA Standard

    Regulations (Standards - 29 CFR)
    Respiratory Protection. - 1910.134

    • Part Number: 1910
    • Part Title: Occupational Safety and Health Standards
    • Subpart: I
    • Subpart Title: Personal Protective Equipment
    • Standard Number: 1910.134
    • Title: Respiratory Protection.
    • Appendix: A ,   B-1 ,   B-2 ,   C ,   D

     

    Appendix E: Emergency Contacts

    Emergency Contact: Mike Machacek, Phone: (320) 761-5250, Phone (After Hours): (320) 761-5250
     
    Back-Up Emergency Contact 1: Wayne Warzecha, Phone: (320) 255-3236, Phone (After Hours):, (320) 293-0397

    Back-Up Emergency Contact 2: Ron Wieber, Phone: (320) 255-3236, Phone (After Hours) (320) 250-4871

     

    The following is a list of additional emergency contacts.

    Fire: 911
    Police: 911
    Ambulance: 911
    Hospital (local): (320) 251-2700 
    Chemtrec: 1-800-424-9300
    Poison Control Center: 1-800-222-1222
    Minnesota Duty Officer: 1-800-422-0798
    National Response Center: 1-800-424-8802
    *U.S. EPA Region 5 Emergency Response Section: (312) 353-2000
    Minnesota Pollution Control Agency: (651) 296-6300
    Weather: (763) 512-1111

    * No provision for 24-hour answering assistance

     

    Appendix F: Respirator Inventory

     

    Appendix G Respirator Change-Out Schedule

     

    Appendix H: Voluntary Respirator Use Statement and Record

     

    Appendix I: Medical Evaluation Questionnaire

    Appendix C to Sec. 1910.134: OSHA Respirator Medical Evaluation Questionnaire (Mandatory) 


    To the employer: Answers to questions in Section 1, and to question 9 in Section 2 of Part A, do not require a medical examination. 

    To the employee: 

    Your employer must allow you to answer this questionnaire during normal working hours, or at a time and place that is convenient to you. To maintain your confidentiality, your employer or supervisor must not look at or review your answers, and your employer must tell you how to deliver or send this questionnaire to the health care professional who will review it. 

    Part A. Section 1. (Mandatory) The following information must be provided by every employee who has been selected to use any type of respirator (please print). 

    1. Today's date:_______________________________________________________ 

    2. Your name:__________________________________________________________ 

    3. Your age (to nearest year):_________________________________________ 

    4. Sex (circle one): Male/Female 

    5. Your height: __________ ft. __________ in. 

    6. Your weight: ____________ lbs. 

    7. Your job title:_____________________________________________________ 

    8. A phone number where you can be reached by the health care professional who reviews this questionnaire (include the Area Code): ____________________ 

    9. The best time to phone you at this number: ________________ 

    10. Has your employer told you how to contact the health care professional who will review this questionnaire (circle one): Yes/No 

    11. Check the type of respirator you will use (you can check more than one category):
    a. ______ N, R, or P disposable respirator (filter-mask, non-cartridge type only).
    b. ______ Other type (for example, half- or full-facepiece type, powered-air purifying, supplied-air, self-contained breathing apparatus). 

    12. Have you worn a respirator (circle one): Yes/No 

    If "yes," what type(s):___________________________________________________________
    _____________________________________________________________ 

    Part A. Section 2. (Mandatory) Questions 1 through 9 below must be answered by every employee who has been selected to use any type of respirator (please circle "yes" or "no"). 

    1. Do you currently smoke tobacco, or have you smoked tobacco in the last month: Yes/No 

    2. Have you ever had any of the following conditions? 

    a. Seizures: Yes/No 

    b. Diabetes (sugar disease): Yes/No 

    c. Allergic reactions that interfere with your breathing: Yes/No 

    d. Claustrophobia (fear of closed-in places): Yes/No 

    e. Trouble smelling odors: Yes/No 

    3. Have you ever had any of the following pulmonary or lung problems? 

    a. Asbestosis: Yes/No 

    b. Asthma: Yes/No 

    c. Chronic bronchitis: Yes/No 

    d. Emphysema: Yes/No 

    e. Pneumonia: Yes/No 

    f. Tuberculosis: Yes/No 

    g. Silicosis: Yes/No 

    h. Pneumothorax (collapsed lung): Yes/No 

    i. Lung cancer: Yes/No 

    j. Broken ribs: Yes/No 

    k. Any chest injuries or surgeries: Yes/No 

    l. Any other lung problem that you've been told about: Yes/No 

    4. Do you currently have any of the following symptoms of pulmonary or lung illness? 

    a. Shortness of breath: Yes/No 

    b. Shortness of breath when walking fast on level ground or walking up a slight hill or incline: Yes/No 

    c. Shortness of breath when walking with other people at an ordinary pace on level ground: Yes/No 

    d. Have to stop for breath when walking at your own pace on level ground: Yes/No 

    e. Shortness of breath when washing or dressing yourself: Yes/No 

    f. Shortness of breath that interferes with your job: Yes/No 

    g. Coughing that produces phlegm (thick sputum): Yes/No 

    h. Coughing that wakes you early in the morning: Yes/No 

    i. Coughing that occurs mostly when you are lying down: Yes/No 

    j. Coughing up blood in the last month: Yes/No 

    k. Wheezing: Yes/No 

    l. Wheezing that interferes with your job: Yes/No 

    m. Chest pain when you breathe deeply: Yes/No 

    n. Any other symptoms that you think may be related to lung problems: Yes/No 

    5. Have you ever had any of the following cardiovascular or heart problems? 

    a. Heart attack: Yes/No 

    b. Stroke: Yes/No 

    c. Angina: Yes/No 

    d. Heart failure: Yes/No 

    e. Swelling in your legs or feet (not caused by walking): Yes/No 

    f. Heart arrhythmia (heart beating irregularly): Yes/No 

    g. High blood pressure: Yes/No 

    h. Any other heart problem that you've been told about: Yes/No 

    6. Have you ever had any of the following cardiovascular or heart symptoms? 

    a. Frequent pain or tightness in your chest: Yes/No 

    b. Pain or tightness in your chest during physical activity: Yes/No 

    c. Pain or tightness in your chest that interferes with your job: Yes/No 

    d. In the past two years, have you noticed your heart skipping or missing a beat: Yes/No 

    e. Heartburn or indigestion that is not related to eating: Yes/No 

    d. Any other symptoms that you think may be related to heart or circulation problems: Yes/No 

    7. Do you currently take medication for any of the following problems? 

    a. Breathing or lung problems: Yes/No 

    b. Heart trouble: Yes/No 

    c. Blood pressure: Yes/No 

    d. Seizures: Yes/No 

    8. If you've used a respirator, have you ever had any of the following problems? (If you've never used a respirator, check the following space and go to question 9:) 

    a. Eye irritation: Yes/No 

    b. Skin allergies or rashes: Yes/No 

    c. Anxiety: Yes/No 

    d. General weakness or fatigue: Yes/No 

    e. Any other problem that interferes with your use of a respirator: Yes/No 

    9. Would you like to talk to the health care professional who will review this questionnaire about your answers to this questionnaire: Yes/No 

    Questions 10 to 15 below must be answered by every employee who has been selected to use either a full-facepiece respirator or a self-contained breathing apparatus (SCBA). For employees who have been selected to use other types of respirators, answering these questions is voluntary. 

    10. Have you ever lost vision in either eye (temporarily or permanently): Yes/No 

    11. Do you currently have any of the following vision problems? 

    a. Wear contact lenses: Yes/No 

    b. Wear glasses: Yes/No 

    c. Color blind: Yes/No 

    d. Any other eye or vision problem: Yes/No 

    12. Have you ever had an injury to your ears, including a broken ear drum: Yes/No 

    13. Do you currently have any of the following hearing problems? 

    a. Difficulty hearing: Yes/No 

    b. Wear a hearing aid: Yes/No 

    c. Any other hearing or ear problem: Yes/No 

    14. Have you ever had a back injury: Yes/No 

    15. Do you currently have any of the following musculoskeletal problems? 

    a. Weakness in any of your arms, hands, legs, or feet: Yes/No 

    b. Back pain: Yes/No 

    c. Difficulty fully moving your arms and legs: Yes/No 

    d. Pain or stiffness when you lean forward or backward at the waist: Yes/No 

    e. Difficulty fully moving your head up or down: Yes/No 

    f. Difficulty fully moving your head side to side: Yes/No 

    g. Difficulty bending at your knees: Yes/No 

    h. Difficulty squatting to the ground: Yes/No 

    i. Climbing a flight of stairs or a ladder carrying more than 25 lbs: Yes/No 

    j. Any other muscle or skeletal problem that interferes with using a respirator: Yes/No 

    Part B Any of the following questions, and other questions not listed, may be added to the questionnaire at the discretion of the health care professional who will review the questionnaire. 

    1. In your present job, are you working at high altitudes (over 5,000 feet) or in a place that has lower than normal amounts of oxygen: Yes/No 

    If "yes," do you have feelings of dizziness, shortness of breath, pounding in your chest, or other symptoms when you're working under these conditions: Yes/No 

    2. At work or at home, have you ever been exposed to hazardous solvents, hazardous airborne chemicals (e.g., gases, fumes, or dust), or have you come into skin contact with hazardous chemicals: Yes/No 

    If "yes," name the chemicals if you know them:_________________________
    _______________________________________________________________________
    _______________________________________________________________________ 

    3. Have you ever worked with any of the materials, or under any of the conditions, listed below: 

    a. Asbestos: Yes/No 

    b. Silica (e.g., in sandblasting): Yes/No 

    c. Tungsten/cobalt (e.g., grinding or welding this material): Yes/No 

    d. Beryllium: Yes/No 

    e. Aluminum: Yes/No 

    f. Coal (for example, mining): Yes/No 

    g. Iron: Yes/No 

    h. Tin: Yes/No 

    i. Dusty environments: Yes/No 

    j. Any other hazardous exposures: Yes/No 

    If "yes," describe these exposures:____________________________________
    _______________________________________________________________________
    _______________________________________________________________________ 

    4. List any second jobs or side businesses you have:___________________
    _______________________________________________________________________ 

    5. List your previous occupations:_____________________________________
    _______________________________________________________________________ 

    6. List your current and previous hobbies:________________________________
    _______________________________________________________________________ 

    7. Have you been in the military services? Yes/No 

    If "yes," were you exposed to biological or chemical agents (either in training or combat): Yes/No 

    8. Have you ever worked on a HAZMAT team? Yes/No 

    9. Other than medications for breathing and lung problems, heart trouble, blood pressure, and seizures mentioned earlier in this questionnaire, are you taking any other medications for any reason (including over-the-counter medications): Yes/No 

    If "yes," name the medications if you know them:_______________________ 

    10. Will you be using any of the following items with your respirator(s)? 

    a. HEPA Filters: Yes/No 

    b. Canisters (for example, gas masks): Yes/No 

    c. Cartridges: Yes/No 

    11. How often are you expected to use the respirator(s) (circle "yes" or "no" for all answers that apply to you)?: 

    a. Escape only (no rescue): Yes/No 

    b. Emergency rescue only: Yes/No 

    c. Less than 5 hours per week: Yes/No 

    d. Less than 2 hours per day: Yes/No 

    e. 2 to 4 hours per day: Yes/No 

    f. Over 4 hours per day: Yes/No 

    12. During the period you are using the respirator(s), is your work effort: 

    a. Light (less than 200 kcal per hour): Yes/No 

    If "yes," how long does this period last during the average shift:____________hrs.____________mins. 

    Examples of a light work effort are sitting while writing, typing, drafting, or performing light assembly work; or standing while operating a drill press (1-3 lbs.) or controlling machines. 

    b. Moderate (200 to 350 kcal per hour): Yes/No 

    If "yes," how long does this period last during the average shift:____________hrs.____________mins. 

    Examples of moderate work effort are sitting while nailing or filing; driving a truck or bus in urban traffic; standing while drilling, nailing, performing assembly work, or transferring a moderate load (about 35 lbs.) at trunk level; walking on a level surface about 2 mph or down a 5-degree grade about 3 mph; or pushing a wheelbarrow with a heavy load (about 100 lbs.) on a level surface. c. Heavy (above 350 kcal per hour): Yes/No 

    If "yes," how long does this period last during the average shift:____________hrs.____________mins. 

    Examples of heavy work are lifting a heavy load (about 50 lbs.) from the floor to your waist or shoulder; working on a loading dock; shoveling; standing while bricklaying or chipping castings; walking up an 8-degree grade about 2 mph; climbing stairs with a heavy load (about 50 lbs.). 

    13. Will you be wearing protective clothing and/or equipment (other than the respirator) when you're using your respirator: Yes/No 

    If "yes," describe this protective clothing and/or equipment:__________
    _______________________________________________________________________ 

    14. Will you be working under hot conditions (temperature exceeding 77 deg. F): Yes/No 

    15. Will you be working under humid conditions: Yes/No 

    16. Describe the work you'll be doing while you're using your respirator(s):
    _______________________________________________________________________
    _______________________________________________________________________ 

    17. Describe any special or hazardous conditions you might encounter when you're using your respirator(s) (for example, confined spaces, life-threatening gases):
    _______________________________________________________________________
    _______________________________________________________________________ 

    18. Provide the following information, if you know it, for each toxic substance that you'll be exposed to when you're using your respirator(s): 

    Name of the first toxic substance:___________________________________________
    Estimated maximum exposure level per shift:__________________________________
    Duration of exposure per shift:______________________________________________
    Name of the second toxic substance:__________________________________________
    Estimated maximum exposure level per shift:__________________________________
    Duration of exposure per shift:______________________________________________
    Name of the third toxic substance:___________________________________________
    Estimated maximum exposure level per shift:__________________________________
    Duration of exposure per shift:______________________________________________
    The name of any other toxic substances that you'll be exposed to while using your respirator:
    _____________________________________________________________________________
    _____________________________________________________________________________
    _____________________________________________________________________________ 

    19. Describe any special responsibilities you'll have while using your respirator(s) that may affect the safety and well-being of others (for example, rescue, security):
    _____________________________________________________________________________

    [63 FR 1152, Jan. 8, 1998; 63 FR 20098, April 23, 1998; 76 FR 33607, June 8, 2011; 77 FR 46949, Aug. 7, 2012]