Respiratory Protection Training Requirements – OSHA
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As you know by now, cutting, drilling, and grinding without using engineering controls can cause exposure to respirable silica to reach much higher than the OSHA PEL.
The level of respiratory protection needed depends on the employee’s silica exposure, which varies due to:
- factors in the work environment (such as enclosed, semi-enclosed, or open spaces and/or multiple operations generating silica dust),
- environmental conditions (such as wind direction and speed), and
- the percentage of silica found in the material.
The good news is respiratory protection should not be necessary when using effective wet methods. In situations where wet methods may not be appropriate or feasible, vacuum dust
collection may be an alternative control option.
However, vacuum dust collection alone does not reduce exposure sufficiently. Therefore, to supplement this control option, employees need to wear a properly fitted, NIOSH-approved
half-facepiece or disposable respirator equipped with an N-, R-, or P-95 filter. A half-facepiece or disposable respirator can be used for exposures up to 1.0 mg/m3.
Respiratory protection is required where specified by Table 1 in OSHA’s 29 CFR 1926.1153, or where
the employer does not fully and properly implement the engineering controls, work practices, and respiratory protection described in the table:
- Where exposures exceed the PEL during periods necessary to install or implement feasible engineering and work practice controls;
- Where exposures exceed the PEL during tasks and engineering and work practice controls are not feasible; and
- During tasks when engineering and work practice controls are not sufficient to reduce exposures to or below the PEL.
Specified Exposure Control Methods
For the tasks listed in 29 CFR 1926.1153, Table 1, if the employer fully and
properly implements the engineering controls, work practices, and respiratory protection described in Table 1, the employer should be considered to be in compliance with:
- the requirements for selection of respirators, and
- with regard to exposure to respirable crystalline silica.
The employer should not allow dry sweeping or dry brushing when it could contribute to employee exposure to silica dust unless wet sweeping, HEPA-filtered vacuuming or other methods
that minimize the likelihood of exposure are not feasible.
- The employer should not allow compressed air to be used to clean clothing or surfaces where such activity could contribute to employee exposure to respirable crystalline silica unless:
- the compressed air is used in conjunction with a ventilation system that effectively captures the dust cloud, or
- no alternative method is feasible.
- Exposed surfaces should be as free as practicable of silica- containing dust (bulk samples of the dust may need to be collected).
- Wet sweeping should be used to clean areas if possible.
- If vacuuming is used for cleaning, the exhaust air should be properly filtered to prevent the release of airborne silica back into the workroom.
- There should be separate break areas for consuming food, beverages, etc. that are kept free of silica.
Respiratory Protection Plan
Respiratory Protection in Construction
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In any workplace where respirators are necessary or required, the employer should establish and implement a written respiratory protection plan with worksite-specific procedures and
elements listed below:
- Employers should conduct exposure monitoring periodically while controls are being used to ensure that the controls are working properly and that the appropriate level of respiratory protection is being used. Other employees working close to where silica dust is generated may also need respiratory protection if effective controls are not implemented.
- The components of an effective Respiratory Protection Program include:
- procedures for selecting respirators for use in the workplace
- medical evaluations required for respirator use
- fit testing procedures for tight-fitting respirators
- procedures for proper respirator use
- procedures and schedules for cleaning and otherwise maintaining respirators
- procedures for atmosphere-supplying respirator proper operation
- training in respiratory hazards during routine and emergency situations
- training in the proper respirator use, limitations and maintenance
- procedures for evaluating respirator program effectiveness
For more information on respiratory protection, review 29 CFR 1910.134
and OSHA’s Respiratory Protection eTool.
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The employer should make medical surveillance available at no cost to the employee, and at a reasonable time and place, for each employee who will be required to use a respirator for 30 or more days
- Initial examination: Employees should get an initial (baseline) medical examination by a physician or Licensed Health Care Professional (PLHCP) within 30 days after initial assignment, unless they have received an examination that meets OSHA requirements within the last three years. The examination should consist of:
- a medical and work history,
- a physical examination with special emphasis on the respiratory system;
- a chest X-ray, interpreted and classified by a NIOSH-certified B Reader;
- a pulmonary function test, administered by a spirometry technician with a current certificate from a NIOSH-approved spirometry course;
- testing for latent tuberculosis infection; and
- any other tests deemed appropriate by the PLHCP.
- Information Provided by the PLHCP: The employer should give the examining PLHCP a copy of related OSHA standards and the following information:
- A description of the employee’s former, current, and anticipated duties;
- The employee’s former, current, and anticipated levels of exposure to respirable crystalline silica;
- A description of any personal protective equipment used or to be used by the employee, including when and for how long the employee has used or will use that equipment; and
- Information from records of employment-related medical examinations.
- PLHCP Report to Employee: The PLHCP should explain the results of the medical examination to the employee and give them a written medical report within 30 days of the examination.
- PLHCP’s Opinion for the Employer: The PLHCP should give the employer a written medical opinion within 30 days of the examination.
- Employer Report to Employees: The employer should give each employee a copy of the written medical opinion within 30 days of each medical examination performed.
- Additional examinations: If the PLHCP believes an employee should be examined by a specialist, the employer should schedule a medical examination within 30 days.
The employer should include respirable crystalline silica in the Hazard Communication program
(29 CFR 1910.1200).
- Each employee should have access to labels on containers of crystalline silica and safety data sheets, and be trained in accordance with the provisions of OSHA’s Hazard Communication Standard (HCS).
- The employer should ensure at least the following hazards are addressed: Cancer, lung effects, immune system effects, and kidney effects.
Employee Information and Training
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The employer should make sure each affected employee demonstrates knowledge and understanding of at least the following:
- The health hazards associated with exposure to respirable crystalline silica;
- Specific tasks in the workplace that could result in exposure to respirable crystalline silica;
- Specific measures the employer has implemented to protect employees from exposure to respirable crystalline silica, including engineering controls, work practices, and respirators to be used;
- The contents of 29 CFR 1926.1153;
- The identity of the competent person designated by the employer; and
- The purpose and a description of the medical surveillance program.
- Air monitoring data: The employer should make and maintain an accurate record of all exposure measurements taken to assess employee exposure to respirable crystalline silica.
Employer exposure records should be maintained and made available to employees upon request.
- Objective data: The employer should make and maintain an accurate record of all objective data relied upon to comply with OSHA requirements.
- Medical surveillance: The employer should make and maintain an accurate record for each employee covered by medical surveillance.
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