CCR Title 8 Section 5144 (GISO Cal OSHA), 29 CFR 1910.134 (GISO Fed OSHA)
Who does it apply to:
All employers whose employees are exposed to an excess of listed OSHA Permissible Exposure Limits (PEL) for applicable substances within the workplace
- Anticipation, Recognition & Evaluation of Chemical Exposures
- (SDS review, job process review, air sampling)
- If air samples exceed listed PELs, then:
- Written Policies and Procedures Development
- Equipment Selection
- (APR/Cartridges, SAR, SCBA, Housing, Sanitizing, Signage)
- Affected Employee Medical Evaluations
- Initial Employee Training and Fit Testing
- Program Maintenance
- Effective Employee Re-Training and Fit Testing (Annual)
- Employee Medical Evaluations, re-evaluations are ONLY required if regulatory triggers are hit.
- Program Maintenance
Many employers do not understand the complexities of the OSHA Respiratory Protection requirements. The bulleted list above notes the primary element requirements of the OSHA Standard, however, OSTS offers its clients one-on-one consultation and classroom-based events to help simplify the needs of a particular Employer’s operations.
OSTS offers all the above-listed services as required of this Standard. First, identifying if there is an actual respiratory protection need is paramount. Many employers implement required and voluntary respiratory protection requirements without evaluating the need based on the actual / potential contaminant exposure(s). Meaning that some employers may be providing respirators to employees where no hazard exists, some employers are providing respiratory protection for employees where the cartridges / filters being used are not appropriate for the actual contaminant, hence, provide a false sense of protection, possibly exacerbating the hazardous exposure.
Common issue / fallacy:
Employers tell us that “we are ONLY providing dust masks” (the white filtering face pieces). Actually there are 10 categories of filtering face pieces and 9 of the 10 categories ARE classified as Respirators. The 9 categories are N95, N99, N100, R95, R99, R100, P95, P99, P100. If on your box or on the face piece you see one of the nine identifying category numbers, your employees are wearing respirators. OSHA requirement states that PRIOR to employees wearing RESPIRATORS even prior to be fit tested, they must complete the medical evaluation process. If you are only protecting employees from nuisances dust, then ensure you are providing dust masks only, unless you wish to implement a required or voluntary use respiratory protection program