David Lahoda, Managing Editor of OSHA Watch and contributor to OSHA Healthcare Advisor, recently blogged on the wake-up call many of us have received as we rush to get our respiratory protection plans up to speed. Organizations are wondering, “If I can get enough N95 respirators to protect my employees, what do I need to do to have my employees wear them?” Lahoda notes that time and planning are needed. Both of which seem to be in short supply right now.
It is impossible to determine what regulators may overlook in the face of a pandemic but the OSHA respiratory protection standard (29 CFR 1910.134) is clear regarding what employers must do to establish a compliant program. The standard requires employers to establish and maintain a written respiratory rotection program that contains the following elements:
Program Administrator - The employer shall designate a program administrator who is qualified by appropriate training or experience that is commensurate with
the complexity of the program.
Respirator Selection - Respirators for protection from pandemic influenza must provide, at the minimum, an N95 protection value and be certified by NIOSH.
Medical Clearance - Employers must evaluate whether employees are able to wear respirators. Evaluation can be performed by respirator clearance questionnaire or by medical examination.
Fit Testing - The standard requires employers to conduct fit testing annually on all employees required to wear respirators with tight-fitting facepieces.
Storage of Respirators - Employers must store respirators in a manner that protects them from contamination and prevents facepiece or valve deformation.
Training and Information - Before requiring respirator use during work, employers must provide training on:
• How improper fit, usage, and maintenance can make respirators ineffective
• The limitations and capabilities of the selected respirator
• How to inspect, put on and remove, and check the seals of the respirator
• Proper respirator maintenance and storage procedures
• The general requirements of the respiratory protection standard
Employers must retrain employees annually and whenever there are changes inworkplace conditions or respirator selection, or whenever there is evidence of improper respirator use.
Are you hustling to get a respiratory protection plan up and running now, or did you heed the advice of OSHA and the CDC years ago and plan ahead?