Environmental Health & Safety

Respiratory Protection Plan

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Introduction:

This program is designed to help reduce employee and student exposure to occupational air contaminants such as: dust, fumes, mists, gasses, vapors, microorganisms, and radionuclides. Where feasible, exposure to contaminants will be eliminated by either engineering controls (i.e., general and local exhaust ventilation, enclosure, or isolation), or substitution of a less hazardous process or material. When effective engineering controls or substitution are not feasible, use of personal protective respiratory equipment may be required. The purpose of this program is to determine the following information:

  • When respiratory protection is needed
  • Which respirators are needed
  • Which employees are required to wear respiratory protection
  • How respirators are used in a correct and safe manner.

This program shall be administered pursuant to the requirements of the OSHA Respiratory Protection Standard, 29CFR 1910.134 (Revised April 8, 1998) attached to this document.

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Responsibilities:

Management: 

Yeshiva University is committed to maintaining a healthful and safe work environment. Yeshiva University is responsible for establishing this respiratory protection program to assist in reducing or eliminating workplace exposure to hazardous materials.

The Environmental Health and Safety Department (EH&S):  

The EH&S Department is responsible for the management of this program. Specific employees in the Department have responsibilities as follows:

  • Chief Safety Officer, EH&S Department:
  • Program Administrator

The YU Safety Specialist and Albert Einstein College of Medicine Industrial Hygienist are charged with the following responsibilities:

  • Coordination and monitoring of the program.
  • Evaluation of the need for respirators including surveillance of conditions and degrees of potential exposure.
  • Modification of the program as appropriate.
  • Identification of employees for participation in the program.
  • Establishment/maintenance of medical surveillance.
  • Coordination of respirator fit testing.
  • Selection of NIOSH-approved respirators and maintenance of respirator inventory.
  • Training sessions for participants regarding use, care, and storage of respirators.
  • Communication of changes in regulatory standards and/or the YU/Albert Einstein College of Medicine Respiratory Protection Program to supervisors and employees.
  • Maintenance of records for this program.

Supervisors are charged with the responsibility to:

  • Insure that all employees are knowledgeable of the respiratory protection requirements for the areas in which they work.
  • Monitor the proper use and care of respirators.
  • Implement a cleaning and inspection program for respiratory equipment, including designation of proper storage areas for respiratory equipment.
  • Enforce employee compliance with the Respiratory Protection Program.
  • Monitor employee compliance with this program. This includes assurance that:
    • Employees who are required to wear a respirator because of potential exposure, do so, as a condition of employment.
    • Employees participate fully in all aspects of the program including medical surveillance and fit testing before wearing a respirator.
    • Employees follow instructions for use, care, storage, and maintenance as outlined by this program.
     

Employees have the responsibility to:

  • Be aware of respiratory protection requirements for their work area.
  • Follow all aspects of this plan including completion of training, medical surveillance, and fit test requirements, prior to using a respirator.
  • The Purchasing Department has the responsibility to order only those respirators approved by the program.

The Medical Exam contractor has the responsibility to:

  • Evaluate physical ability of employees to wear a respirator.
  • Communicate written results to YU Safety Specialist or Albert Einstein College of Medicine Industrial Hygienist, as appropriate.
  • Fit-Testing contractor is charged with the fit testing of all participants in the Respiratory Protection Program.

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Selection of Respiratory Protective Equipment:

Evaluation of Potential Hazards: 

Operations and processes will be monitored for potential respiratory hazards, according to accepted industrial hygiene practices.

Personal sampling equipment may be used in accordance with accepted industrial hygiene standards to sample an area. Decisions regarding the use of respiratory protection may be based upon these results or by a reasonable and conservative estimate of these hazards.

Respirator use is mandatory in areas considered hazardous and will comply with 29 CFR 1910.134 or 1926.110.

Voluntary use of respirators is not permitted in areas that are considered non-hazardous at YU and Albert Einstein College of Medicine.

Types of respirators:  

  • Air-purifying respirators clean the contaminated atmosphere through the use of filters, absorbents, or chemicals. Air-purifying respirators can only be used where there is sufficient oxygen to sustain life and the air contaminant level is within specified limitations of the respirator.
  • Mechanical-filter, air-purifying respirators provide protection against airborne particulate matter including: dusts, mists, metal fumes, smokes, and microorganisms, but do not provide protection against gases, vapors, or oxygen deficiency.
  • Chemical-cartridge air-purifying respirators provide protection against certain gases and vapors by using various chemical filters to purify the inhaled air.
  • The Occupational Safety and Health Administration (OSHA) requires that NIOSH approved air-purifying respirators be used by workers.

Atmosphere or air-supplying respirators provide breathable air from a source of air which is independent from the ambient atmosphere. There are three classes of atmosphere-supplying respirators:  

  • Supplied-air respirators
  • Self-contained breathing apparatuses (SCBA)
  • Combination-SCBA and supplied-air respirators. The use of SCBA equipment may be required in specific areas for emergency use. Only appropriately trained employees may use SCBA at YU/Albert Einstein College of Medicine.

Combination air-purifying and atmosphere-supplying devices have an auxiliary air-purifying attachment, which provides protection in the event the air supply fails.

WORKERS USING RESPIRATORS MUST BE SPECIFICALLY TRAINED FOR THE RESPIRATOR THEY ARE PLANNING TO USE.

Respirators currently approved by Environmental Health and Safety Department are:

  • Half-face respirator - (3M 7000)
  • Full-face respirator - (3M 6000)
  • PAPR respirator - (3M/MASHA)
  • N95 respirator for TB (Tecnol)

The following cartridges are available at the EH&S Department. Listed are their colors and usage:

  • Purple (Magenta) - Particulates (dust, mist, fumes, asbestos, and radionuclides)
  • White - Acid gas
  • Black - Organic vapor
  • White with 1/2" green strip - HCl
  • Yellow - Acid gases and organic vapor
  • Green - Ammonia
  • Blue - Carbon monoxide
  • Colors vary (N95) - T.B. Exposure
  • YU/Albert Einstein College of Medicine shall ensure that all filters, cartridges, and canisters used in the workplace are labeled and color-coded with the NIOSH approval label and that the label is intact and legible.

Selection of Respirators: 

Wherever respiratory protection is required, NIOSH-approved respirators, appropriate to the hazards, shall be selected by the Albert Einstein College of Medicine EH&S Department.

Selection is based upon physical and chemical properties of air contaminants and concentration levels likely to be encountered by employees.

Respirators will be made immediately available to each new hire or transferee to a job where respiratory protection is required.

Respirators shall be selected in compliance with all relevant regulatory requirements (29CFR 1910.134 and 29CFR 1926.1101).

Areas where respirators may be required: 

Respiratory protection shall be required in any work area that has the potential to create an environment where the atmospheric contamination levels exceed the OSHA permissible exposure limits (PELs) for the specific contaminant.

Respiratory protection is always required to be worn in accordance with 29CFR 1926.1101 in any area where workers' tasks may disturb known or potential asbestos-containing material.

Self-contained breathing apparatuses may be required to be worn when filtered respirators are not adequate. These may include areas with insufficient oxygen, where contaminants are at a level Immediately Dangerous to Life or Health (IDLH), or the contaminant levels are unknown.

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Medical Evaluation:

For N95 Respirator users

Prior to the issuance of a respirator all employees shall complete a medical questionnaire. (See 29 CFR 1910.134 Appendix C.) This questionnaire must be approved by a Physician or Licensed Health Care Professional (PLHCP) before issuance of an N95 respirator.

Medical examinations will be given to any employee at the discretion of the PLHCP.

For Half-Face, Full-Face, PAPR, and SCBA Respirator users

Prior to the issuance of a respirator all employees shall complete a medical questionnaire, (See 29 CFR 1910.134 Appendix C.), and receive a medical exam to determine the employee's physical ability to wear a respirator. This exam shall be provided without cost to each eligible employee.

Content of Medical Evaluations: 

  • A complete occupational and medical history update
  • A complete physical
  • Pulmonary function testing to include Forced Expiratory Volume at one second (FEVI), Forced Vital Capacity (FVC) and the FEVI -to- FVC ratio.
  • Chest X-ray and GI evaluation for asbestos workers at the discretion of the (PLHCP).
  • Any other test deemed medically appropriate by the examining PLHCP.

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FIT TESTING:

The proper fit of respiratory equipment to the user is determined by a qualitative fit test procedure according to 29 CFR 1910.134 Appendix A.

Employees who take part in this program are not permitted to wear beards unless they provide:

  • A documented religious reason
  • A documented medical condition

 

Employees must provide EH&S with a written personal statement for a religious exemption and a written physician's statement for a medical exemption. Respiratory protection for these employees will be evaluated on a case-by-case basis.

Fit testing shall be performed according to the following schedule:

  • Prior to issuance of a respirator, but after medical clearance.
  • Annually for both Asbestos and Non-Asbestos workers.
  • If any of the following conditions occur
    • Significant weight gain or loss
    • Dental changes
    • Facial scarring
    • Cosmetic surgery
     

 

Employees are responsible to check their respirators for fit prior to each use by performing negative and positive seal checks as described in 29 CFR 1910.134 Appendix B-1. If these checks are not successful, the respirator should not be used.

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Respirator Use:

Employees must pass both the medical examination and the fit test in order to wear a respirator.

Employees may not wear a respirator if they have facial hair which comes between the sealing surface of the facepiece and the face or any condition which interferes with the face to facepiece seal or valve function.

Employees who wear respirators are permitted to leave the regulated area to wash their faces and respirator facepieces as necessary. This may be done to prevent skin irritation associated with respirator use or to change the filter elements if a change in breathing resistance or chemical vapor breakthrough is detected.

Every employee is required to perform a negative and positive seal check prior to respirator use.

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Maintenance of Respiratory Protective Equipment:

All respirators shall be maintained using the procedures in 29 CFR 1910.134 Appendix B-2 or procedures recommended by the manufacturer, provided that such procedures are of equivalent effectiveness. The following methods shall be used to maintain the equipment:

Cleaning/Disinfecting:
Respiratory equipment shall be washed thoroughly in warm water with detergent, using a soft brush. Detergents with a bactericide are preferable. If detergent with a bactericide is not used, the detergent wash shall be followed with a disinfecting rinse. Components shall be hand-dried with a clean lint free cloth or air dried before assembly.

Storage:
Dry, clean, disinfected respirators shall be sealed in clean plastic bags out of direct sunlight with the facepiece and exhalation valve in a non-distorted position.

Repair:
Repair and replacement of damaged parts must be done before the respirator can be used. Replacement parts must be those of the manufacturer of the equipment. Replacement parts are available from either Engineering or the EH&S Department. Repairs or replacement must be performed by a qualified individual.

Inspection Procedures:
All respirators shall be inspected by each user before and after each use and during cleaning. The following items will be examined during inspection:

  • Rubber Facepiece
  • Cracked or broken air-purifying element holder(s), badly worn threads or missing gasket(s)
  • Excessive dirt
  • Cracks, tears, or holes
  • Distortion
  • Cracked, scratched, or loose-fitting lens (full face)
  • Incorrectly mounted full facepiece lens or broken/missing mounting clips

 

Head Strap  

  • Breaks or tears
  • Loss of elasticity
  • Broken or malfunctioning buckles/attachments
  • Excessively worn serrations on head piece
  • Harness which might allow the facepiece to slip

 

Inhalation/Exhalation valves  

  • Detergent residue, dust particles, dirt, or hair on valve or valve seat.
  • Cracks, tears, distortion in valve material or valve seat
  • Improper insertion of the valve body in the facepiece
  • Cracks, breaks, or chips in the valve body particularly in the sealing surface
  • Improper installation of the valve in the valve body

 

Filter elements  

  • Incorrect cartridge, canister, or filter for the hazard
  • Missing or worn gaskets
  • Worn threads
  • Cracks or dents in filter housing
  • Incorrect installation, loose connections, or cross-threading in holder
  • Evidence of prior use of sorbent, cartridge, or canister, indicated by absence of sealing material, tape foil, etc. over inlet

 

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Training

All employees in the program will be trained annually in the proper use and care of their respiratory equipment that have been assigned to them.

Training will include the following elements:

  • Why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator
  • What the limitations and capabilities are for the respirator
  • How to use the respirator effectively in routine and emergency situations, including situations in which the respirator malfunctions
  • How to inspect, doff and don, use, and check the seals of the respirator
  • What the procedures are for maintenance and storage of the respirator
  • How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators.

 

The training shall be conducted in a manner that is understandable to the employee.

The employer shall provide the training prior to requiring the employee to use a respirator in the workplace.

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Program Evaluation

Surveillance of the workplace will be conducted by the EH&S Department on an ongoing basis to determine the necessity of respiratory protection.

This program will be reviewed and updated periodically via:

  • Review of training rosters
  • Review of medical evaluation records
  • Review of fit testing rosters
  • Observation of compliance with care, use, and storage
  • Enforcement of the program
  • Review and observation of the appropriateness and competence of the fit testing program.

 

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Record Keeping

Records will be maintained at the EH&S and will include the following:

  • Medical Evaluations
  • Fit Testing
  • A written copy of The YU/Albert Einstein College of Medicine Respiratory Protection Program
  • A copy of the OSHA Standard 29 CFR 1910.134

 

All written materials are available at the YU and Albert Einstein College of Medicine Environmental Health and Safety Office upon request.

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Contacts

EH&S can be contacted at (718) 430-4150 for questions or clarifications regarding this Respiratory Protection Program.

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For more information see: 29 CFR 1910.134 

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