OSHA’s Most Common Citations: Respiratory Protection Programs

It’s all about breathing easy.

In this ongoing series of blogs about the U.S. Occupational Safety and Health Association’s (OSHA’s) list of 10 most cited standards, we now come to the issue of respiratory protection programs.

Sometimes, the best way to protect workers against airborne chemicals in the workplace is to use respirators. Unfortunately, it’s not as simple as buying some facemasks out of the respiratory protection catalog and handing them out to workers. A respiratory protection program requires a fair bit of legwork to create and implement.

You may need a respiratory protection program (29 CFR 1910.134) if your workers are exposed to a hazardous level of an airborne contaminant, and their exposure cannot be reduced below the OSHA permissible exposure limit through the use of engineering controls (for example, substitution or mechanical ventilation), or if workers are exposed to oxygen-deficient atmospheres. You may also require workers to wear respirators if you deem it necessary, regardless of published exposure limits. Or, workers may choose to wear respirators even though you do not require it. In any of these situations, you will need a compliant respiratory protection program.

Your respiratory protection program must be overseen by a specific, qualified individual, and must also be administered at no cost to the employee. It should include:

  • A discussion of the hazard characterization and respirator selection process.
  • The details of how workers will be medically evaluated to determine that they can safely wear a respirator.
  • The fit testing procedures that will be used, and records of workers’ fit tests.
  • Procedures for proper use, storage and maintenance of respirators, as well as schedules for the replacement of respirator cartridges.
  • Details of the initial and annual retraining program for respirator users.
  • Regular program evaluation.

One final consideration that may challenge the success of your respiratory protection program: respirators can be hot and uncomfortable. They can impair a worker’s visibility, irritate skin and make it harder to do heavy, physical work. They impose physical constraints on workers, who must be clean-shaven in order to maintain the respirator’s protection effectiveness, and respirators are easy to misuse. It’s not unusual to get a lot of pushback and resistance from workers. It’s important that you have a clear idea of what the hazards are, why they can’t be controlled another way, and what the consequences are for workers who don’t wear respirators when required – not just the health consequences, but potential disciplinary consequences as well.

Each year, OSHA tallies up the citations it has issued and publishes a list of the 10 most cited standards. There are about a half-dozen standards that almost always make that list. Respiratory protection is one.

Check out the entire list of OSHA’s Most Common Citations and How You Can Avoid Them in a report published by Intelex Technologies. It is available as a free download.

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