SPOTLIGHT ON SAFETY
Respirator Fit Testing for Immediately Dangerous to Life or Health Atmospheres Doug Prentiss Sr.
ver the years I have gotten many questions about fit testing for respirators, and this article will attempt to combine clarifications for the most confusing parts of the regulations covering the issue. Perhaps one of the sources of the confusion is the way it is presented in the regulation. Repeated throughout the regulation is the following comment: “Whether the employer chooses qualitative or quantative fit testing, as if it is just a convenience or arbitrary decision, the decision on fit testing type is driven by the potential exposure for the workers.” The foundation of the respiratory protection standard starts with the knowledge of the employer about the actual hazards workers will face. The employer is directly responsible for determining specific worker hazard exposure potential, and that hazard potential is the key that some fail to see. Nuisance dusts or low exposure levels can be handled by a simple respiratory program that allows for qualitative fit tests and checklist health evaluations. When we put workers in immediately dangerous to life or health (IDLH) situations that can kill them if they don’t follow procedures or use personal protective equipment (PPE), we are held to a higher standard, which is reflected by quantative fit testing. So, if your workers are using respirators for protection, look at the IDLH level on the material safety data sheets (MSDS) and determine if their exposure could go higher than 10 times the permissible exposure level for the chemical. A simple example is if your workers use a chlorine cartridge for respiratory protection for minor leaks and you use 1 parts per million (ppm) as the permissible exposure level. A cartridge will provide respiratory protection up to 10 ppm, so when combined with work procedures that evacuate the worker before reaching IDLH, the fit testing and health as-
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sessment could be qualitative because the worker will not reach IDLH. Confined spaces, where the worker’s ability to escape is hampered, may change the potential and add additional requirements. Determination of IDLH potential can also be determined by use of gas detectors or other atmospheric monitors. Sometimes work activities, such as welding and cutting, can also create IDLH atmospheres with toxic fumes. Fortunately, many industry standards for performing hazardous work exist and are used on a regular basis. For those of you who will have to explain this to your workers or others, I provide the follow notes from the respiratory protection standard. 1910.134(d)(1) General requirements. 1910.134(d)(1)(i) The employer shall select and provide an appropriate respirator based on the respiratory hazard(s) to which the worker is exposed, and workplace and user factors that affect respirator performance and reliability. 1910.134(d)(1)(iii) The employer shall identify and evaluate the respiratory hazard(s) in the workplace; this evaluation shall include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant's chemical state and physical form. Where the employer cannot identify or reasonably estimate the employee exposure, the employer shall consider the atmosphere to be IDLH.
and Health (NIOSH) for a minimum service life of thirty minutes, or 1910.134(d)(2)(i)(B) A combination full facepiece pressure-demand supplied-air respirator (SAR) with auxiliary self-contained air supply. 1910.134(e) Medical evaluation. Using a respirator may place a physiological burden on employees that varies with the type of respirator worn, the job, workplace conditions in which the respirator is used, and the medical status of the employee. Accordingly, this paragraph specifies the minimum requirements for medical evaluation that employers must implement to determine the employee's ability to use a respirator. 1910.134(e)(1) General. The employer shall provide a medical evaluation to determine the employee's ability to use a respirator, before the employee is fittested or required to use the respirator in the workplace. The employer may discontinue an employee's medical evaluations when the employee is no longer required to use a respirator. 1910.134(f) Fit testing. Before an employee may be required to use any respirator with a negative or positive pressure tight-fitting facepiece, the employee must be fit-tested with the same make, model, style, and size of respirator that will be used.
1910.134(d)(2) Respirators for IDLH atmospheres.
1910.134(d)(2)(i) The employer shall provide the following respirators for employee use in IDLH atmospheres:
1910.134(d)(2)(i) The employer shall provide the following respirators for employee use in IDLH atmospheres:
1910.134(d)(2)(i)(A) A full facepiece pressure-demand SCBA certified by NIOSH for a minimum service life of thirty minutes, or
1910.134(d)(2)(i)(A) A full facepiece pressure-demand self-contained breathing apparatus (SCBA) certified by the National Institute for Occupational Safety
1910.134(d)(2)(i)(B) A combination full facepiece pressure-demand supplied-air respirator (SAR) with auxiliary self-contained air supply.
September 2016 • Florida Water Resources Journal