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Common Mistakes in Compliance with OSHA Standard for Respiratory Protection

Written By:  Robert E. Sheriff, CIH, CSP, President
March 6, 2020

Common Mistakes in Compliance with OSHA Standard for Respiratory Protection

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.  Sampling the worker with a battery-powered personal sampler or a badge is the appropriate method of determining exposure and OSHA Compliance.

“Objective Data” from the monitoring of similar work situations is acceptable.  Objective Data is the use of sampling results from a similar operation—as a means to determine if the worker exposure is safe and acceptable.

  1. NIOSH Approved Respirators 1910.134 (d) (1) (ii) and selection using Assigned Protection Factor Table 1 1910.134 (d) (3) (i) (a). Don’t just go to the local building supply store and buy a “three-pack” of whatever dust mask or respirator you use.  An Industrial Hygienist or another qualified competent person must determine from sampling results what is the appropriate respirator or dust mask.
  2. 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.  If an individual is exposed to the OSHA regulated substances for 30 days or longer in a given year, an appropriate physical and medical history questionnaire is required to be authorized to wear a respirator.

  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.  It is important to note that this is an annual requirement.

  1. Voluntary Use of Respirators 1910.134 Appendix D

This is a mandatory section of the Respiratory Protection 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.”  Many OSHA Citations have been issued for facial hair along the respirator sealing surface. 

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, email us at info@atlenv.com or fill out our contact form.

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