Written Respiratory Protection Program
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27Respiratory Protection
The Occupational Safety and Health Administration (OSHA) construction
industry regulations relating to respiratory protection (29 CFR 1926.103) are
actually found under the general industry regulations applicable to respiratory
protection in 29 CFR 1910.134. Those provisions mandate respiratory protection
if engineering controls are not feasible or are ineffective. OSHA requires
methods such as substituting less toxic materials or ventilating the work area to
prevent atmospheric contamination. When engineering controls fail to reduce
employee exposures to harmful contaminants below the permissible exposure
limit (PEL) of a contaminant, respiratory protection and accompanying program
elements must be put in place.
Written Respiratory Protection Program
The OSHA respiratory standard requires contractors to develop and implement a
written respiratory protection program for situations in which PELs of airborne
contaminants could be exceeded or when the employer requires use of
respirators by workers. See also the chapter on Confined Spaces.
The written program also must address voluntary respirator use; respirator
selection; medical evaluations; fit-testing; use of respirators; user seal checks;
maintenance and care of respirators; identification of filters, cartridges and
canisters; employee training; and program evaluation. The standard requires the
respiratory program to be administered by a program administrator and updated
to reflect the changing workplace conditions that affect respirator use. The
standard sets out several mandatory components within the aforementioned
program categories including fit testing, seal-check and cleaning procedures in
addition to a medical evaluation questionnaire and voluntary-use procedures that
are compiled in appendices to §1910.134.
Many of the elements listed may not need to change for each project. For
example, medical evaluations, fit-test procedures, schedules and procedures for
maintaining respirators, air-quality requirements for supplied-air respirators,
employee training and program evaluations often can remain consistent. The
only change that may be needed in a work-site specific written program is the
procedure for respirator selection. (The procedures for respirator selection are
addressed later in this chapter.)
When employees voluntarily wear respiratory protection, the employer still must
establish and implement written respiratory program components related to the
medical evaluation of a worker’s ability to wear the respirator safely. Elements
relating to cleaning, storing and maintaining respirators must be addressed, as
well. Employees must be provided with copies of the information contained in
Appendix D of the standard titled “Information for Employees Using Respirators
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