Supervisors
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:
- Ensuring that employees under their supervision
(including new hires) have received appropriate training,
fit testing, and annual medical evaluation.
- Ensuring the availability of appropriate respirators
and accessories.
- Being aware of tasks requiring the use of respiratory
protection.
- Enforcing the proper use of respiratory protection
when necessary.
- Ensuring that respirators are properly cleaned,
maintained, and stored according to the respiratory
protection plan.
- Ensuring that respirators fit well and do not cause
discomfort.
- Continually monitoring work areas and operations to
identify respiratory hazards.
- Coordinating with the Program Administrator on how to
address respiratory hazards or other concerns regarding
the program.
Employees
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:
- Only wear the respirator for the conditions specified
in the Fit Test Letter (see Appendix
A)
- Care for and maintain their respirators as
instructed, and store them in a clean sanitary
location.
- Inform their supervisor or EHRS if the respirator no
longer fits well, and request a new one that fits
properly.
- Inform their supervisor or the Program Administrator
of any respiratory hazards that they feel are not
adequately addressed in the workplace and of any other
concerns that they have regarding the program.
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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:
- Identification and development of a list of hazardous
substances used in the workplace, by department, or work
process.
- Review of work processes to determine where potential
exposures to these hazardous substances may occur. This
review shall be conducted by surveying the workplace,
reviewing process records, and talking with employees and
supervisors.
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:
- Employees may wear disposable N95 respirators when
working in animal areas.
- Physical Plant workers may wear disposable N95
respirators for dusty operations.
The Program Administrator will provide all employees who
voluntarily choose to wear respirators with a copy of Appendix D of the standard. (Appendix
D 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 medical evaluation will be conducted using the
questionnaire provided in Appendix C of the respiratory protection standard. The Program
Administrator will provide a copy of this questionnaire
to all employees requiring medical evaluations.
- To the extent feasible, Penn will assist employees
who are unable to read the questionnaire (by providing
help in reading the questionnaire). When this is not
possible, the employee will be sent directly to the
medical practitioner for medical evaluation.
- All affected employees will be given a copy of the
medical questionnaire to fill out and they will bring the
completed questionnaire to the medical practitioner.
Employees will be permitted to fill out the questionnaire
on company time.
- Follow-up medical exams will be granted to employees
as required by the standard, and/or as deemed necessary
by the medical practitioner.
- All employees will be granted the opportunity to
speak with the medical practitioner about their medical
evaluation, if they so request.
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):
- a summary of the employee's exposure to a hazardous
substance
- his or her work area or job title
- proposed respirator type and weight
- length of time required to wear respirator
- expected physical work load (light, moderate, or
heavy)
- potential temperature and humidity extremes
- any additional protective clothing required
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:
- Employee reports signs and/or symptoms related to
their ability to use a respirator, such as shortness of
breath, dizziness, chest pains, or wheezing.
- A physician informs the Program Administrator that
the employee needs to be reevaluated;
- Information from the program, including observations
made during fit testing and program evaluation, indicates
a need for reevaluation;
- A change occurs in workplace conditions that may
result in an increased physiological burden on the
employee.
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:
- Prior to being allowed to wear any respirator with a
tight fitting facepiece.
- Annually.
- When there are changes in the employee's physical
condition that could affect respiratory fit (e.g.,
obvious change in body weight, facial scarring,
etc.).
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.
The following procedure is to be used when cleaning
and disinfecting respirators:
- Disassemble respirator, removing any filters,
canisters, or cartridges.
- Wash the facepiece and associated parts in a mild
detergent with warm water. Do not use organic
solvents.
- Rinse completely in clean warm water.
- Wipe the respirator with disinfectant wipes (70%
Isopropyl Alcohol) to kill germs.
- Air dry in a clean area.
- Reassemble the respirator and replace any defective
parts.
- Place in a clean, dry plastic bag or other air tight
container.
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:
Facepiece:
cracks, tears, or holes
facemask distortion
cracked or loose lenses/faceshield
Headstraps:
breaks or tears
broken buckles
Valves:
residue or dirt
cracks or tears in valve material
Filters/Cartridges:
approval designation
gaskets
cracks or dents in housing
proper cartridge for hazard
Air Supply Systems:
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:
- Temporarily take the respirator out of service until
it can be repaired.
- Perform a simple fix on the spot such as replacing a
headstrap.
- Dispose of the respirator due to an irreparable
problem or defect.
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:
- The University of Pennsylvania Respiratory Protection
Program
- The OSHA Respiratory Protection standard
- Respiratory hazards encountered at University of
Pennsylvania and their health effects
- Proper selection and use of respirators
- Limitations of respirators
- Respirator donning and user seal (fit) checks
- Fit testing
- Emergency use procedures (if applicable)
- Maintenance and storage
- Medical signs and symptoms limiting the effective use
of respirators
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.
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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.
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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.
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MEMORANDUM
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
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MEMORANDUM
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.
- The type and weight of the respirator that
will be used:
- The duration and frequency of the respirator
use:
- The expected physical work effort:
- Additional protective clothing and equipment that
will be worn:
- Temperature and humidity extremes experienced during
work:
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
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FIT TEST RECORD
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.
You should do the following:
- Read and heed all instructions provided by the
manufacturer on use, maintenance, cleaning and care, and
warnings regarding the respirators limitations.
- Choose respirators certified for use to protect
against the contaminant of concern. NIOSH, the National
Institute for Occupational Safety and Health of the U.S.
Department of Health and Human Services, certifies
respirators. A label or statement of certification should
appear on the respirator or respirator packaging. It will
tell you what the respirator is designed for and how much
it will protect you.
- Do not wear your respirator into atmospheres
containing contaminants for which your respirator is not
designed to protect against. For example, a respirator
designed to filter dust particles will not protect you
against gases, vapors, or very small solid particles of
fumes or smoke.
- Keep track of your respirator so that you do not
mistakenly use someone else's respirator.
Updated: October 20, 2005