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Common Mistakes in Compliance with OSHA Standard for Respiratory Protection

Written By: Robert E. Sheriff, CIH, CSP, President

June 25, 2019

 

Year after year, citations for violations of the Respiratory Standard 1910.134 consistently remain in the TOP 5 most cited OSHA violations.

 

Don’t kid yourself, respiratory protection is a complex subject. You cannot just arbitrarily decide that “it looks dusty out there, I guess I will have the workers wear dust masks.”

 

Here are some of the most common mistakes made by employers related to respiratory protection:

 

  1. Monitoring (1910.134 (d) (1) (iii)

In order to select the proper respirator, you must monitor the workers’ exposure levels to determine the level of exposure in order to select the proper respirator. Just follow the information on a Safety Data Sheet (SDS) is not sufficient.

 

“Objective Data” from the monitoring of similar work situations is acceptable.

 

  1. NIOSH Approved Respirators 1910.134 (d) (1) (ii) and selection using Assigned Protection Factor Table 1 1910.134 (d) (3) (i) (a).

 

  1. Medical Evaluation 1910.134 (e)

A determination of whether an employee is capable of wearing a respirator must be performed before a worker is fit tested or required to use the respirator in the workplace.

 

  1. Initial and Annual Fit Testing and Training 1910.134 (f) (1) d (f) (2)

The regulation is specific in what specific aspects of respiratory protection use and care must be included in the training and included in the Respiratory Protection Program.

 

  1. Voluntary Use of Respirators 1910.134 Appendix D

This is a mandatory section of the standard to be provided to employees who choose to wear a respirator when not required under the Standard. Appendix D must be given to any employee who voluntarily wears a respirator.

 

The employer can voluntarily provide a respirator but is not required to do so. The employee can select their own respirator.

 

  1. Facial Hair 1910.134 Appendix A.0.9 Fit Testing Procedures (Mandatory) Appendix A specifically states:

“The test shall not be conducted if there is any hair growth between the skin and the facepiece sealing surface, such as stubble beard growth, beard, mustache or sideburns which cross the respirator sealing surface. Any type of apparel which interferes with a satisfactory fit shall be altered or removed.”

 

Note that the fines for OSHA Citations have increased dramatically in the past several years. For 2019 they include:

 

         Serious Violation – $13,260.00.

         MOST RESPIRATORY PROTECTION CITATIONS ARE CONSIDERED SERIOUS.

        

         Repeat Violation – $132,598.00.

         Failing to correct a previously cited respiratory protection citation.

 

Also Note:   Many of the 21 States Plan States have not raised their fines from $7,000.00.

State Plans: AK, HI, CA, OR, WA, NV, AZ, UT, WY, NM, MN, IA, MI, IN, KY, TN, SC, NC, VA, MD, VT.

 

If you need assistance with Respiratory Protection or Respiratory Protection Program, contact us at 1-800-344-4414, by email at info@atlenv.com or fill out our online contact form.

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