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Respiratory Protection Program

When effective engineering controls are not feasible, or while being instituted, Occupational Safety and Health Administration ("OSHA") requires that respirators are used to protect employees from breathing contaminated and/or oxygen-deficient air. When controls do not reduce respiratory hazards beneath established exposure limits, appropriate respirators shall be used.

Background

It is the commitment of Dow Aero Logistics ("Company") to maintain a safe and healthy work environment. Management and all employees alike are responsible for establishing and maintaining good health and safety practices. 

When effective engineering or administrative controls are not feasible or practical, or in the event of emergency situations, it may be necessary to use personal respiratory protective equipment, in combination with other personal protective equipment (PPE). An effective program is essential in ensuring adequate protection for employees using respirators.

Objective

The Respiratory Protection Program works to provide a safe and healthy work environment for employees that use respirators by:

  • Establishing accepted practices for respirator use;
  • Providing guidelines for training and respirator selection; and
  • Explaining proper storage, use, and care of respirators.

Scope

This program applies to all Company employees who need to wear a respirator to perform assigned duties. Any employee who voluntarily wears a respirator, other than filtering face pieces (e.g. dust masks), is subject to Respirator Use and Safety training and examination, medical evaluation, along with respirator cleaning, maintenance, and storage elements as outlined in this program.

Responsibilities

Environmental Health and Safety

Environmental Health and Safety (EH&S) is responsible for developing, implementing, and administering the Respiratory Protection Program. As the Respiratory Protection Program Administrator, additional EH&S responsibilities include:

  • Evaluating overall effectiveness of the Respiratory Protection Program and updating accordingly.
  • Regularly assessing respiratory hazards in work areas.
  • Providing guidance to managers and supervisors on the selection and purchase of appropriate respirators.
  • Supplying or coordinating training (including refresher sessions) on the proper use, maintenance, and storage of respirators to all it's users.
  • Issuing instructions to respirator users that are to be medically evaluated.
  • Collecting medical evaluation results and determining proper next steps.
  • Providing a fit testing program for respirator users.
  • Approving/Rejecting employees from conducting work that requires respirator use.
    • Approving/Rejecting employees seeking voluntary respirator use.
  • Maintaining records on respiratory protective equipment assignments, fit testing, and training.

Direct Managers and Supervisors

Direct managers and supervisors have the primary responsibility of implementing the Respiratory Protection Program in their work area(s). This involves:

  • Overseeing employees in order to ensure that they're following all applicable elements of the Respiratory Protection Program.
  • Identifying jobs/tasks that may require respiratory protection, providing this information to Environmental Health and Safety (EH&S), and seeking EH&S assistance in evaluating respiratory hazards.
  • Purchasing appropriate respirators and making them available for authorized use.
  • Enforcing the proper use of respiratory protection.
  • Ensuring that respirators are properly cleaned, maintained, and stored in accordance with this the Respiratory Protection Program.
  • Confirming that required respirator users, under their supervision (including new hires), receive appropriate training, are medically evaluated, fit tested, and approved to conduct tasks requiring a respirator by Environmental Health and Safety (EH&S).
    • Confirming that voluntary respirator users, under their supervision, receive appropriate training, are medically evaluated, and approved to conduct tasks requiring a respirator by Environmental Health and Safety (EH&S).
    • Recognizing changes in jobs/tasks which may require re-evaluation of respirator use and notifying EH&S in these situations.

    Respirator Users

    Respirator users must follow the requirements of the Respiratory Protection Program. This involves:

    • Using the respirator in accordance with the manufacturer's instructions and training received.
    • Storing, cleaning, maintaining, and guarding against damage to the respirator.
    • Reporting any respirator malfunction to the direct manager and/or Environmental Health and Safety (EH&S).
    • Inspecting the respirator before each use.
    • Promptly reporting any symptoms of illness that may be related to respirator usage or exposure to hazardous atmospheres to the direct manager and/or EH&S.
    • Informing the direct manager and/or EH&S of operation changes or health status changes that could affect safe use of the equipment.

    Licensed Healthcare Professional

    The licensed healthcare professional is responsible for:

    • Performing initial medical evaluations, as well as conducting any necessary follow-up examinations, to determine an employee's ability to wear a respirator.
    • Providing an evaluation of the employee's ability to use a respirator to Environmental Health and Safety (EH&S).
    • Conducting periodic medical evaluation of respirator users, as necessary and when notified by Environmental Health and Safety (EH&S).

    Workplace Exposure Assessment

    Initially and whenever management or employees identify new substances, processes, or equipment that may represent an occupational safety and health hazard, they shall contact Environmental Health and Safety (EH&S) for a workplace exposure assessment:

    Based on the information provided and potential follow-up correspondence, EH&S will determine if respiratory protection is necessary.

    Program Evaluation

    Environmental Health and Safety (EH&S) and other appropriate management shall conduct workplace evaluations to ensure that the provisions of the current Respiratory Protection Program are implemented and effective.  

    To assist with program evaluation, required respirator users shall fill out a Respirator Use Annual Questionnaire to communicate any problems or concerns. Any problem that EH&S identifies from this questionnaire shall be corrected immediately, with either permanent or temporary action.

      Training

      Training for Required Respirator Usage

      Any employee required to wear a respirator shall receive training in the proper use, care, and limitations of each respirator, with specialized training for the type of respirator(s) that will be used by the user. The training course will cover the following topics:

      • The Company's Respiratory Protection Program.
      • Respiratory hazards encountered at the workplace and their health effects.
      • Proper selection and use of respirators.
      • Limitations of respirators.
      • Respirator donning and user fit checks.
      • Fit testing.
      • Maintenance and storage.
      • Medical signs and symptoms limiting the effective use of respirators.

      Each of these employees shall be trained upon initial assignment and at least once every twelve (12) months thereafter. Retraining shall also be provided whenever:

      • Workplace or respirator changes render previous training obsolete.
      • Deficiencies in the employee’s knowledge are revealed.
      • Other situation arises that signifies that retraining appears necessary.

      Training for Voluntary Respirator Usage

      Before voluntary respirator use is approved, an employee must receive an approved medical evaluation and complete initial training for the proper use, care, and limitations of the selected respirator. The employee shall then review, sign, and submit the Voluntary Respirator Use Agreement provided by Environmental Health and Safety (EH&S).

        Medical Clearance

        Before any employee is fit tested for respirator use in the workplace, a medical evaluation shall be provided to determine the employee's ability to use a respirator. A medical evaluation is not required for employees needing to use dust masks or escape-only respirators (i.e. emergency life support apparatuses, or ELSAs).

        Medical Evaluation

        Employees shall be given an initial medical evaluation to determine if they are medically capable to use a respirator. This includes:

        • Completing a Respirator Medical Evaluation Questionnaire.
        • If necessary, a follow-up medical exam shall include medical tests, consultations, and/or diagnostic procedures ordered by a licensed healthcare professional.

        Environmental Health and Safety (EH&S) will provide respirator users with appropriate materials/instructions when a medical evaluation is needed.

        Provision of Supplemental Information to the Evaluating Licensed Healthcare Professional

        Prior to making any determination regarding an employee’s ability to wear a respirator, the evaluating licensed healthcare professional shall be given:

        • A written copy of the Company's Respirator Protection Program.
        • Specific information regarding the employee’s respirator usage.
          • This shall include the expected respirator to be used by the employee.
          • Chemical compounds and/or formulations the employee will be exposed to in a work area(s) where a respirator will be used.

        Medical Determination

        Required Elements

        The licensed healthcare professional shall provide a written recommendation regarding the employee’s ability to use the respirator. The recommendations shall provide only the following information:

        • Any limitations on respirator use related to the medical condition of the employee, or relating to the workplace conditions in which the respirator will be used, including whether or not the employee is medically capable of using the respirator.
        • The need, if any, for follow-up medical evaluations.
        • A confirmation that the licensed healthcare professional has provided the employee with a copy of the written recommendation.

        Alternative Respirators

        If the licensed healthcare professional identifies a medical condition that may place the employee's health at increased risk during assigned use of a negative-pressure respirator, then a powered air-purifying respirator (PAPR) shall be approved for use so long as the licensed healthcare professional's evaluation indicates that it would be suitable. If a subsequent medical evaluation finds the employee medically capable to use a negative-pressure respirator, the physician must indicate this in a written recommendation.

        Additional Medical Evaluations

        Medical evaluations shall be promptly provided whenever:

        • An employee reports medical signs or symptoms that affects his or her ability to use a respirator.
        • When a licensed healthcare professional, supervisor, direct manager, or Environmental Health and Safety (EH&S) personnel believes that an employee needs to be re-evaluated.
        • Information gathered from training/fit testing personnel or records that indicates the need for employee re-evaluation.
        • A change in conditions that may result in a substantial increase in the physiological burden placed on an employee.
          • e.g. physical work effort, protective clothing, or temperature.

        Respirator Selection

        Environmental Health and Safety (EH&S) and/or other appropriate management shall select appropriate respirators and accessories that will provide adequate protection for all employees for specific operations and/or expected contaminants.

        General Consideration

        The selection of a proper respirator for any given situation shall require evaluation of workplace respiratory hazards, including identification of:

        • Determining the contaminant’s chemical state (valence state) and physical form (e.g. gas, vapor, particulate, etc.).
        • A reasonable estimate of employee exposures to respiratory hazard(s).

        Approved Respirators, Filters, Cartridges, and Canisters

        • Only respirators certified by the National Institute of Occupational Safety and Health (NIOSH) shall be selected.
        • All appropriate filters, cartridges, and canisters shall be labeled and color-coded with NIOSH approved labels.
          • Labeling shall not be removed and must remain legible.

        Respirators, filters, cartridges, and canisters are not to be modified in anyway unless in accordance with manufacturer instruction. Writing on respirators shall only occur on the straps and should only list the employee's identification number, or the employee, department, and/or Company name. Filters, cartridges, and canisters shall have their initial use date written on an appropriate area that does not interfere with the item's effectiveness. 

        Respirators for Use

        Protection Against Particulates

        Where appropriate, respirator users shall be provided with an air-purifying respirator or air-supplying respirator equipped with a NIOSH-certified HEPA (high-efficiency particulate air) filter, or with a NIOSH-rated filter rated at N95 or higher.

        Protection Against Gases and Vapors

        Respirator users shall be provided with either an air-purifying respirator or air-supplying respirator, as appropriate. If an air-purifying respirator is selected:

        • The respirator shall be equipped with an end-of-service-life indicator (ESLI) certified by NIOSH for the specific contaminant.
          • If no appropriate ESLI can be used, employees shall follow the manufacturer appropriate cartridge/canister change schedule.

        Respirators for Use in IDLH Atmospheres

        The only kinds of respirators authorized for use in an atmosphere immediately dangerous to life and health (IDLH) are:

        • A full-facepiece pressure-demand SCBA (self-contained breathing apparatus) certified by NIOSH for a minimum service life of 30 minutes.
        • A combination full-facepiece pressure-demand supplied-air respirator with auxiliary self-contained air supply.

        Respirator Fit Test

        A respirator fit test shall be performed on employees slated to wear tight-fitting facepiece respirators.

        General Requirements

        Where respirator use is required, fit testing shall be conducted:

        • Prior to initial use and at least annually.
        • Whenever an employee switches to a new or different tight-fitting facepiece (size, style, model, or make).
        • Whenever the employee reports, or the licensed healthcare professional, supervisor, direct manager, Environmental Health and Safety (EH&S), or other appropriate members of management notice changes in the employee’s physical condition that could affect respirator fit.
          • e.g. facial scarring, dental changes, cosmetic surgery, or obvious changes in body weight.

        For air-supplying respirators and that are tight-fitting facepieces, fit testing shall be performed in a negative-pressure mode.

        Respirator fit testing procedures shall follow general standards. This includes using qualitative and quantitative fit testing methods when and where appropriate.

        • Qualitative fit testing is a pass/fail test method that uses your sense of taste or smell, or your reaction to an irritant in order to detect leakage into the respirator facepiece. Qualitative fit testing does not measure the actual amount of leakage; the test is simply based on you detecting leakage of the test substance into your facepiece.
          • Qualitative fit testing is normally used for half-mask respirators (cover only your mouth and nose).
          • The Bitrex solution aerosol testing protocol may be used for qualitative fit testing.
        • Quantitative fit testing uses a machine to measure the actual amount of leakage into the facepiece and does not rely upon your sense of taste, smell, or irritation in order to detect leakage. The respirators used during this type of fit testing will have a probe attached to the facepiece that will be connected to the machine by a hose. 
          • Quantitative fit testing may be used for all tight-fitting respirators.

        Fit Testing for Voluntary Respirator Use

        Fit testing is not required for voluntary use of respirators (for purposes of comfort).

        Authorization for Use

        Any respirator use, either required or voluntary, shall be pre-approved by the employee's direct manager and Environmental Health and Safety (EH&S). Employees shall only wear the specific respirator type(s) for which they were pre-approved.

        Note that the voluntary use of filtering facepieces (dust masks) does not fall under the requirements of the Respiratory Protection Program.

        Respirator Use Approval

        The following instructions apply only to Company employees required to wear respirators:

        1. Complete Respirator Use and Safety training course and pass the examination.

          • A 70% or higher result is required to pass the training exam.

        2. Complete a Respirator Medical Evaluation Questionnaire.

          • This may be completed online (instructions will be provided once the user has been identified to be tested).

            • If necessary, an employee may be required to submit to an off-site location for further evaluation.

          • Results will identify whether any respirator type or use restrictions exist.

          • Note that this is only required for first-time respirator use approval or when deemed necessary.

        3. Once you've passed the Respirator Use and Safety training examination and have been provided approved medical clearance, Environmental Health and Safety (EH&S) will schedule respirator fit testing.

          • Based on fit testing results, a specific respirator model and size will be assigned.

        Upon completing the steps above, Environmental Health and Safety EH&S will provide Company certification permitting respirator approval for one year at the specific premise(s) and respirator type(s) permitted.

        Respirator Use

        Facepiece Seal Protection

        A tight-fitting facepiece respirator shall not be worn when conditions prevent the respirator from properly sealing to the wearer. Remedies to common facepiece seal problems include:

        • Shaving facial areas that interfere with face-to-facepiece seal or areas that interfere with respirator valve function.
        • Ensure glasses and personal protective equipment are worn in such a way as to avoid facepiece seal interference.

        User Seal Checks

        To ensure that an adequate seal is achieved each time the respirator is put on, use either the positive/negative pressure check or the respirator manufacturer’s recommended user seal check method. User seal checks are not substitutes for qualitative or quantitative fit tests. Refer to the Respiratory Use and Safety training course for specific user seal check procedures.

        Change Schedules for Respirators, Filters, Cartridges, and Canisters

        Respirators, filters, cartridges, and canisters shall be replaced as determined by manufacturer recommendations, including end-of-service-life indicators (ESLI). A direct manager and/or Environmental Health and Safety (EH&S) may also develop specific change schedules where deemed necessary.

        Continued Respirator Effectiveness

        When a conditional change occurs in an employee's work area or when the degree of employee hazardous exposure increases this can lead to added stress for both the respirator and user, which can affect the respirator's effectiveness to protect the employee. Should situations arise, the employee, supervisor, and/or direct manager shall request Environmental Health and Safety (EH&S) to re-evaluate respiratory hazards in their impacted work area(s).

        Maintenance and Care of Respirators

        Each respirator shall be properly cared for and maintained to remain effective. This requires cleaning and disinfecting, properly storing, conducting periodic inspections, and only proceeding with manufacture-approved repairs.

        Cleaning and Disinfecting

        Respirator users must clean and sanitize their respirators, as covered in the Respiratory Use and Safety training course and maintain the following schedule:

        • An individually assigned respirator, which is used routinely, shall be cleaned as often as necessary to maintain a sanitary condition.  
        • Respirators that are not individually assigned shall be cleaned and disinfected before each use.
        • Respirators kept for emergency use or fit testing shall be cleaned and disinfected after each use.

        Storage

        Respirator users must properly store their respirators, in accordance with manufacture directions and as covered in the Respiratory Use and Safety training course.

        Periodic Inspections

        Respirator users shall inspect their respirators before each use and when cleaning, in accordance with manufacture directions and as covered in the Respiratory Use and Safety training course. 

        Respirator periodic inspections shall be documented on the Respirator Periodic Inspections Record (consult your direct manager for location of this record at your worksite).

        Repair

        Respirators that do not pass inspection shall be removed from service and brought to the attention of the employee's direct manager or Environmental Health and Safety (EH&S) immediately.

        • Minor repairs shall be made as specified by the respirator manufacturer’s instructions, and while only using the manufacturer’s NIOSH-approved parts. 
          • (e.g. replacing valves for air-purifying respirators or replacing straps)
        • No attempt shall be made to replace components, or make adjustments, modifications, or repairs beyond the manufacturer's recommendation.
          • If a manufacturer indicates that a respirator cannot be repaired by the user, the unit shall be disposed of, or the manufacturer should be contacted for further assistance.
        • Reducing and admission valves, regulators, and alarms shall only be adjusted or repaired by the manufacturer or a manufacturer-trained technician.

        Recordkeeping

        Environmental Health and Safety (EH&S) shall ensure that records of the following are maintained:

        • Employee medical clearance form.
        • Employee respirator training records.
        • Employee respirator fit testing records.

        The direct manager shall ensure that records of the following are maintained:

        • Respirator inspection and maintenance records.

        The licensed healthcare professional will maintain employee medical questionnaires, along with any additional documentation as required.


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