University of Pennsylvania has determined that certain employees are exposed to respiratory hazards during routine operations. These hazard include, chemical vapors, certain biohazards, asbestos and other particulates. The purpose of this program is to ensure that all University of Pennsylvania employees and students are protected from exposure to these respiratory hazards.
Engineering controls, such as ventilation and substitution of less toxic materials, are the first line of defense at University of Pennsylvania; however, engineering controls are not always feasible for some of our operations, or do not always completely control the identified hazards. In these situations, respirators and other protective equipment must be used. Respirators are also needed to protect employee health during emergencies. The work activities requiring respirator use at University of Pennsylvania are outlined in Table 1 in the Scope and Application section of this program.
In addition, some employees have expressed a desire to wear respirators during certain operations that do not require respiratory protection. As a general policy University of Pennsylvania will review each of these requests on a case-by case basis. As outlined in the Scope and Application section of this program, voluntary respirator use is subject to certain requirements of this program.
This program applies to all employees who are required to wear respirators during normal work operations, and during some non-routine or emergency operations such as a spill of a hazardous substance. This includes employees in the EHRS, ULAR and faculty and staff involved in certain research activities. All employees working in these areas and engaged in certain processes or tasks (as outlined in table that follows) must be enrolled in the Penn's respiratory protection program.
|
Work Process |
Type of Respirator |
|
Chemical Hazards |
Full face Air-purifying Respirator (APR) |
|
Biohazards |
N95 disposable |
|
Asbestos Management |
Half, Full face Air-purifying Respirator (APR) or Powered Air-purifying Respirator (PAPR) |
|
Pesticide Application |
Powered Air-purifying Respirator (PAPR) or half face Air-purifying Respirator (APR) |
|
Emergency response |
Half, Full FaceAir-purifying Respirator (APR),Self-Contained Breathing Apparatus (SCBA), Powered Air-purifying Respirator (PAPR) |
The Program Administrator is responsible for administering the respiratory protection program. Duties of the program administrator include:
The Program Administrator for University of Pennsylvania is Lisa Krause.
Supervisors are responsible for ensuring that the respiratory protection program is implemented in their particular areas. In addition to being knowledgeable about the program requirements for their own protection, supervisors must also ensure that the program is understood and followed by the employees under their charge. Duties of the supervisor include:
Each employee has the responsibility to wear his or her respirator when and where required and in the manner in which they were trained. Employees must also:
The Program Administrator will select respirators to be used on site, based on the hazards to which workers are exposed and in accordance with all OSHA standards. The Program Administrator will conduct a hazard evaluation for each operation, process, or work area where airborne contaminants may be present in routine operations or during an emergency. The hazard evaluation will include:
The hazard evaluation may include exposure monitoring to quantify potential hazardous exposures. Monitoring will be conducted if the industrial hygienist conducting the evaluation determines that it is required. Monitoring will be performed by EHRS staff when needed.
All respirators must be certified by the National Institute for Occupational Safety and Health (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 approval label. The label must not be removed or defaced while it is in use.
Supplied air and air purifying respirators will be used depending on the emergency. Appropriate respiratory protection will be selected by the Incident commander or the Safety Officer.
Disposable N95 or disposable respirators are the only Voluntary Use respirator permitted by The University of Pennsylvania. University of Pennsylvania does not permit its employees to use their own respirators.
Penn may provide disposable N95 respirators filtering respirators at no charge to employees for voluntary use for the following work processes:
The Program Administrator will provide all employees who voluntarily choose to wear respirators with a copy of Appendix D of the standard. ( details the requirements for voluntary use of respirators by employees and is included as Appendix D of this document).
The Program Administrator shall authorize voluntary use of respiratory protective equipment as requested by all other Penn employees on a case-by case basis, depending on specific workplace conditions and the results of the medical evaluations.
Employees who are required to wear respirators, or have special permission by EHRS to voluntarily wear a reusable air-purifying respirator (APR), must pass a medical exam before being permitted to wear a respirator on the job. Employees are not permitted to wear respirators until a physician has determined that they are medically able to do so. Any employee refusing the medical evaluation will not be allowed to work in an area requiring respirator use.
Medical evaluations are provided by a physician, or other licensed healthcare professional (PLHCP) at one of the following locations (where most workers compensation medical services are provided):
1) Faculty/Staff on main campus and at Morris Arboretum: Occupational Medicine at the Hospital of the University of Pennsylvania.
2) Students on main campus: Student Health at Penn Tower.
3) Faculty/Staff at New Bolton Center: The Occupational Health Center of Kennett Square.
In some cases other licensed physicians may provide the evaluation. Medical evaluation procedures are as follows:
The Program Administrator has provided the Hospital of the University of Pennsylvania, and Student Health physician with a copy of this Respirator program. In addition the following is provided for each employee in a letter to requesting medical evaluation (see Appendix B):
In special cases where other licensed physicians provide the medical exam, the Program Administrator will provide the same information.
After an employee has received clearance and starts to wear his or her respirator, additional medical evaluations will be provided under the following circumstances:
All examinations and questionnaires are to remain confidential between the employee and the physician.
Fit testing is required for Penn employees who are required to wear respirators. Employees voluntarily wearing half-facepiece APRs may also be fit tested upon request.
Employees who are required to wear half-facepiece APRs will be fit tested:
Employees will be fit tested with the make, model, and size of respirator that they will actually wear. Employees will be provided with several models and sizes of respirators so that they may find an optimal fit. Fit testing of PAPRs shall be conducted in the negative pressure mode if worn with a tight fitting facepiece.
The Program Administrator will conduct fit tests following the OSHA approved Irritant smoke QLFT Protocol, or the Bitter Aerosol QLFT Protocol in the Respiratory Protection standard.
The Program Administrator has determined that QNFT is not required for the respirators used under current conditions at University of Pennsylvania. If conditions affecting respirator use change, the Program Administrator will evaluate on a case-by-case basis whether QNFT is required.
Employees will use their respirators under conditions specified by this program, and in accordance with the training they receive on the use of each particular model. In addition, the respirator shall not be used in a manner for which it is not certified by NIOSH or by its manufacturer or for an exposure or work activity that is not approved by EHRS.
All employees not wearing disposable N95 respirators shall conduct user seal checks each time that they wear their respirator. Employees shall use either the positive or negative pressure check (depending on which test works best for them) specified in Appendix B-1 of the Respiratory Protection Standard.
All employees shall be permitted to leave the work area to maintain their respirator for the following reasons: to clean their respirator if the respirator is impeding their ability to work, change filters or cartridges, replace parts, or to inspect respirator if it stops functioning as intended. Employees should notify their supervisor before leaving the area.
For any malfunction of an APR (e.g., such as breakthrough, facepiece leakage, or improperly working valve), the respirator wearer should inform his or her supervisor that the respirator no longer functions as intended, obtain a replacement. The supervisor must ensure that the defective respirator is returned to EHRS for service.
All workers wearing atmosphere-supplying respirators will work with a buddy. Buddies shall assist workers who experience an SAR malfunction as follows:
If a worker experiences a malfunction of an SAR, he or she should signal to the buddy that he or she has had a respirator malfunction. The buddy shall don an emergency escape respirator and aid the worker in immediately exiting the work area.
For supplied-air respirators, only Grade D breathing air shall be used in the cylinders. The Program Administrator or his designee will coordinate refill of compressed air cylinders for SCBAs with an appropriate vendor.
The Program Administrator will maintain an air supply of 4 fully charged replacement cylinders for its SCBAs. The air for this system is provided by Penn's supplier, and deliveries of new air are coordinated by the Program Administrator or his designee.
Respirators are to be regularly cleaned and disinfected at a suitable location.
Respirators issued for the exclusive use of an employee shall be cleaned as often as necessary.
Atmosphere supplying and emergency use respirators are to be cleaned and disinfected after each use.
Note: The employee's supervisor will ensure an adequate supply of appropriate cleaning and disaffection material at the cleaning station. If supplies are low, employees should contact their supervisor who will order the needed supplies.
Respirators are to be properly maintained at all times in order to ensure that they function properly and adequately protect the employee. Maintenance involves a thorough visual inspection for cleanliness and defeats. Worn or deteriorated parts will be replaced prior to use. No components will be replaced or repairs made beyond those recommended by the manufacturer. Repairs to regulators or alarms of atmosphere-supplying respirators will be conducted by a service agent licensed by the manufacturer of the SAR.
Inspection of the respirator must be conducted before every use. The following checklist will be used when inspecting respirators:
cracks, tears, or holes
facemask distortion
cracked or loose lenses/faceshield
breaks or tears
broken buckles
residue or dirt
cracks or tears in valve material
approval designation
gaskets
cracks or dents in housing
proper cartridge for hazard
breathing air quality/grade
condition of supply hoses
hose connections
settings on regulators and valves
Employees are permitted to leave their work area to perform limited maintenance on their respirator in a designated area that is free of respiratory hazards.
Respirator users are informed of the proper cartridge change schedule during annual training. For more information on cartridge change schedules, contact the Program Administrator Lisa Krause, at 215-898-4453.
Respirators must be stored in a clean, dry area, and in accordance with the manufacturer's recommendations. Each employee will clean and inspect their own air-purifying respirator in accordance with the provisions of this program and will store their respirator in a plastic bag in their own emergency response bag or other suitable location.
Atmosphere supplying respirators will be stored in the Tandem Waste building and on the emergency response truck.
The Program Administrator will supply respirators and respirator components in their original manufacturer's packaging in EHRS, the Tandem Waste building and on the emergency response truck.
Respirators that are defective or have defective parts shall be take out of service and given to the Program Administrator. If, during an inspection, an employee discovers a defect in a respirator, he/she is to bring the defect to the attention of his or her supervisor. Supervisors will give all defective respirators to the Program Administrator who will decide whether to
When a respirator is taken out of service for an extended period of time, the respirator will be tagged out of service, and the employee will be given a replacement of similar make, model, and size. All tagged out respirators will be kept in the Program Administrator's office.
The Program Administrator will provide training to respirator users and their supervisors on the contents of the University of Pennsylvania Respiratory Protection Program and their responsibilities under it, and on the OSHA Respiratory Protection standard. Workers will be trained prior to using a respirator in the workplace. Supervisors will also be trained prior to using a respirator in the workplace or prior to supervising employees that must wear respirators.
The training course will cover the following topics:
Employees will be retrained annually or as needed (e.g., if they change departments and need to use a different respirator). Employees must demonstrate their understanding of the topics covered in the training through hands-on exercises, i.e. correctly donning and doffing the respirator. Respirator training will be documented by the Program Administrator and the documentation will include the type, model, and size of respirator for which each employee has been trained and fit tested.
The Program Administrator will conduct periodic evaluations of the workplace to ensure that the provisions of this program are being implemented. The evaluations will include regular consultations with employees who use respirators and their supervisors, site inspections, air monitoring and a review of records.
Problems identified will be noted in a lab notebook. These finding will be reported to employee's supervisor and will specific corrective actions and target dates for the implementation of those corrections.
A written copy of this program and the OSHA standard is kept in the EHRS office and is available to all employees who wish to review it.
Also maintained in the EHRS office are copies of training and fit test records. These records will be updated as new employees are trained as existing employees receive refresher training, and as new fit tests are conducted.
The Program Administrator will also maintain copies of the medical clearance records for all employees covered under the respirator program. The completed medical questionnaire and documented findings are confidential and will remain with the appropriate medical practitioner. EHRS will only retain written recommendation regarding each employee's ability to wear a respirator.
To: Name
From:
Date:
Re: Respirator use
This is to confirm that you received training and passed a qualitative respirator fit test with the following equipment:
Respirator Manufacturer:
Model:
Type:
Size:
You may only use this respirator for the following tasks:
Specify conditions and tasks
You should not use this respirator for any chemical or biological exposure or activity not listed above without approval from this office. This fit test must be repeated before Date.
In addition to the respirator you must wear list other PPE if applicable
You were also provided with list other hazard awareness information such as MSDS or other literature provided to the employee if applicable
Please contact me if you have any questions.
Encl. File: Respirator Program/emp. fit test
To: To whom it may concern
From:
Date:
Re: Medical evaluation for respirator use.
NAME, a University of Pennsylvania employee, is required to wear a respirator at work. The University of Pennsylvania requests that you provide this employee with a medical evaluation that meets the requirements outlined in the Occupation Health and Safety Administration's Respirator Standard, 1910.134 paragraph (e). We have provided you with this portion of the Respirator Standard. Please follow this procedure when you examine this employee.
An OSHA Respirator Medical Evaluation Questionnaire was provided to this employee. A completed questionnaire must be provided to you by the employee.
The following supplemental information is provided to you to assist in your evaluation of this employee's respirator use.
We request that you provide the Environmental Health and Radiation Safety Office with a signed statement on letterhead indicating that the employee is medically able to wear a respirator under the conditions described.
Please feel free to contact me if you have any questions.
Encl.: 1910.134 (e) and OSHA Respirator Medical
Evaluation Questionnaire
File: Respirator Program/emp. fit test
Name of respirator user:______________________________
Test Date:_________
Position Title:____________________________________________________
Department:______________________________________________________
Location:________________________________________________________
Challenge Agent Used: Isoamyl Acetate Saccharin
Bitrex Irritant Smoke
Respirator Make: Survivair North MSA Racal 3M
Moldex Wilson Other:
Respirator Model:________________
Respirator Size:__________________
Additional PPE Worn:_____________________________________________________
__________________________________________________________
Comments: ______________________________________________________________
______________________________________________________________
PASS / FAIL
Next fit-test due:___________
Information for Employees who Voluntarily Use Respirators
SubPart Title: Personal Protective Equipment
APPENDIX D to Sec. 1910.134 (Mandatory) Information for Employees Using Respirators When Not Required Under the Standard
Respirators are an effective method of protection against designated hazards when properly selected and worn. Respirator use is encouraged, even when exposures are below the exposure limit, to provide an additional level of comfort and protection for workers. However, if a respirator is used improperly or not kept clean, the respirator itself can become a hazard to the worker. Sometimes, workers may wear respirators to avoid exposures to hazards, even if the amount of hazardous substance does not exceed the limits set by OSHA standards. If your employer provides respirators for your voluntary use, of if you provide your own respirator, you need to take certain precautions to be sure that the respirator itself does not present a hazard.