sample 1910 134 respiratory protection program 99

8/14/2019 sample 1910 134 respiratory protection program 99

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_______________________

Fire Department

Respiratory Protection Program

OSHA 1910.134

1999

Revised Date:

January 19, 1999

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1.0 Purpose______________________________________________ has determined that employees in the_________________________________________ Department are exposed to respiratoryhazards during routine operations. These hazards include smoke particulates, and vapors, and insome cases represent Immediately Dangerous to Life or Health (IDLH) conditions. The purposeof this program is to ensure that all __________________________ employees are protectedfrom exposure to these respiratory hazards.

Positive pressure Self Contained Breathing Apparatus (SCBA) are the first line of defense at__________________________ Department. In IDLH situations, respirators and otherprotective equipment must be used. Respirators will be used to protect employees health duringemergencies. The work requiring respirator use at __________________________ Departmentare outlined in Table 1 in the Scope and Application section of this program.

In addition, some employees have expressed a desire to wear respirators during certain operationsthat do not require respiratory protection. As a general policy ___________________

Department will review each of these requests on a case-by-case basis. If the use of respiratoryprotection in a specific case will not jeopardize the health or safety of the worker(s),__________________________ will provide respirators for voluntary use. As outlined in theScope and Application section of this program, voluntary respirator use is subject to certainrequirements of this program.

2.0 Scope and ApplicationThis program applies to all employees who are required to wear respirators during normal workoperations, and during some non-routine or emergency operations. This includes employeesworking in fire suppression and the hazardous materials incidents. All employees working in theseareas and engaged in certain operations or tasks (as outlined in the table below) must be enrolled

in the companys respiratory protection program.

In addition, any employee who voluntarily wears a respirator when a respirator is not required(i.e., in certain maintenance and training operations) is subject to the medical evaluation,cleaning, maintenance, and storage elements of this program, and must be provided with certaininformation specified in this section of the program.

Employees participating in the respiratory protection program do so at no cost to them. Theexpense associated with training, medical evaluations and respiratory protection equipment will beborne by the department.

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TABLE 1:VOLUNTARY AND REQUIRED RESPIRATOR USE AT _________________________

Respirator Department/Process

( )Filtering facepiece dust mask

Voluntary use in dust environments

, 30SCBA minute open circuit

positive pressure

-Fire Suppression IDLH

environments


positive pressure

-Fire Suppression IDLH

environments


positive pressure

-Hazardous Materials Incidents

IDLH environments

3.0 Responsibilities

Program Administrator The Program Administrator is responsible for administering the respiratory protection

program. Duties of the program administrator include:

Identifying work areas, processes or tasks that require employees to wearrespirators, and evaluating hazards.

Selection of respiratory protection options. Monitoring respirator use to ensure that respirators are used in accordance with

their certifications. Arranging for and/or conducting training. Ensuring proper storage and maintenance of respiratory protection equipment. Conduct or oversee fit testing. Administering the medical surveillance program. Maintaining records required by the program.

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Evaluating the program. Updating written program, as needed.

The Program Administrator for _______________________________ Department is______________________________.

Supervisors/Company OfficersSupervisors/Company Officer are responsible for ensuring that the respiratory protection programis implemented by employees. In addition to being knowledgeable about the programrequirements for their own protection, Supervisors/Company Officer must also ensure that theprogram is understood and followed by the employees under their charge. Duties of thesupervisor include:

Ensuring that new employees under their supervision have received appropriate fittesting, training, and medical evaluation.

Ensuring that employees under their supervision have received appropriate training,annual fit testing, and necessary medical re-evaluation.

Ensuring the availability of appropriate respirators and accessories. Being aware of tasks requiring the use of respiratory protection.

Enforcing the proper use of respiratory protection when necessary. Ensuring that respirators are properly cleaned, maintained, and stored according to

the respiratory protection plan. Ensuring that respirators fit well and do not cause discomfort. Continually monitoring work areas and operations to identify respiratory hazards. Coordinating with the Program Administrator on how to address respiratory hazards

or other concerns regarding the program.

EmployeesEach employee has the responsibility to wear his or her respirator when and where required and inthe manner in which they were trained. Employees must also:

Care for and maintain assigned respirator facepiece as instructed, and store them in aclean sanitary location.

Inform their supervisor if the respirator facepiece no longer fits well, and request anew one that fits properly.

Inform their supervisor or the Program Administrator of any respiratory hazards thatthey feel are not adequately addressed in the workplace and of any other concerns thatthey have regarding the program.

4.0 Program Elements

Selection ProceduresThe Program Administrator will select respirators to be used on site, based on the hazards towhich workers are exposed and in accordance with all OSHA standards. The ProgramAdministrator will conduct a hazard evaluation for each operation, process, or work area whereairborne contaminants may be present in routine operations or during an emergency. The hazardevaluation will include:

1)Identification and development of a list of hazardous substances used in the workplace,by department, or work process.

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2)Review of work processes to determine where potential exposures to these hazardoussubstances may occur. This review shall be conducted by surveying the workplace,reviewing process records, and talking with employees and Supervisors/Company Officer.3) Exposure monitoring to quantify potential hazardous exposures. Additional

monitoring will be contracted out to services to provide monitoring when needed.

The results of the current hazard evaluation are the following:(Table 3 at the end of this program contains the data that this section was based on.)

Fire Suppression Interior Structure__________________________ has decided to take a conservative approach and require allemployees to wear SCBA respirators when working inside the operations areas at incidents.Based on exposure data in published reports on this type of incident, the Program Administratorhas determined that an SCBA in positive pressure mode will provide sufficient protection.

Positive pressure SCBA are required for employees involved with fire suppression activities.

Ventilation controls on structure incidents will be in place, but employees will continue to wearand use while inside the operations area.

Fire Suppression Vehicles and Transportation__________________________ has decided to take a conservative approach and require allemployees to wear SCBA respirators when working inside the operations areas at incidents.Based on exposure data in published reports on this type of incident, the Program Administratorhas determined that an SCBA in positive pressure mode will provide sufficient protection.

Fire Suppression Grass and Vegetation__________________________ has decided to take a conservative approach and require all

employees to be prepared to wear SCBA respirators when working inside the operations areas atincidents. Based on exposure data in published reports on this type of incident, the ProgramAdministrator has determined that an SCBA in positive pressure mode and some cartridge filtermasks will provide sufficient protection.

While __________________________ notes that respiratory protection is not required in thisarea, the department recognizes employee concern about breathing vapors and about having towork in an unpleasant environment. Accordingly, employees may voluntarily choose to wearSCBA when working in this area.

Hazardous Materials Incidents__________________________ has decided to take a conservative approach and require allemployees to wear SCBA respirators when working inside the operations areas at incidents.Based on exposure data in published reports on this type of incident, the Program Administratorhas determined that an SCBA in positive pressure mode will provide sufficient protection in mostincidents however each situation will be evaluated on a case by case basis.Confined Space Incidents__________________________ has decided to take a conservative approach and require all

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employees to wear SCBA respirators when working inside the operations areas at incidents.Based on exposure data in published reports on this type of incident, the Program Administratorhas determined that an SCBA in positive pressure mode will provide sufficient protection in mostincidents however each situation will be evaluated on a case by case basis.

Training Evolutions__________________________ has decided to take a conservative approach and require allemployees to wear SCBA respirators when working in areas where artificial smoke is being used.Based on exposure data in published reports on this type of smoke, the Program Administratorhas determined that an SCBA in positive pressure mode will provide sufficient protection in mostsituations however each situation will be evaluated on a case by case basis.

Department Maintenance Activities:Because of potential IDLH conditions, employees must wear a positive pressure SCBA during theperformance of there maintenance activities that require SCBA.

Although exposure monitoring has shown that exposures are kept within PELs during these

procedures, __________________________ will provide respirators to workers who areconcerned about potential exposures.

Updating the Hazard AssessmentThe Program Administrator must revise and update the hazard assessment as needed (i.e., anytime work process changes may potentially affect exposure). If an employee feels thatrespiratory protection is needed during a particular activity, he/she is to contact his or hersupervisor/company officer or the Program Administrator. The Program Administrator willevaluate the potential hazard, arranging for outside assistance as necessary. The ProgramAdministrator will then communicate the results of that assessment back to the employees. If it isdetermined that respiratory protection is necessary, all other elements of this program will be in

effect for those tasks and this program will be updated accordingly.

NIOSH CertificationAll respirators must be certified by the National Institute for Occupational Safety and Health(NIOSH) and shall be used in accordance with the terms of that certification. Also, all filters,cartridges, and canisters must be labeled with the appropriate NIOSH approval label. The labelmust not be removed or defaced while it is in use.

Voluntary Respirator Use__________________________ will provide respirators at no charge to employees for voluntaryuse for the following work processes:

Employees may wear organic vapor cartridge filtering respirators while working in thevegetation incidents.

EMS workers may wear filtering facepiece.

The Program Administrator shall authorize voluntary use of respiratory protective equipment asrequested by all other workers on a case-by-case basis, depending on specific workplaceconditions and the results of the medical evaluations.

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Medical EvaluationEmployees who are either required to wear respirators, or who choose to wear respiratorsvoluntarily, must pass a medical exam before being permitted to wear a respirator on the job.Employees are not permitted to wear respirators until a physician has determined that they aremedically able to do so. Any employee refusing the medical evaluation will not be allowed towork in an area requiring respirator use. Any employee who does not comply with facial hairrules will not wear respirators.

A licensed physician at ABC medical clinic, where all company medical services are provided, willprovide the medical evaluations. Medical evaluation procedures are as follows:

The medical evaluation will be conducted using the questionnaire provided inAppendix C of 1910.134 the respiratory protection standard. The ProgramAdministrator will provide a copy of this questionnaire to all employees requiringmedical evaluations.

To the extent feasible, the department will assist employees who are unable to readthe questionnaire (by providing help in reading the questionnaire). When this is

notpossible, the employee will be sent directly to the physician for medical evaluation.

All affected employees will be given a copy of the medical questionnaire to fill out,along with a stamped and addressed envelope for mailing the questionnaire to thecompany physician. Employees will be permitted to fill out the questionnaire ondepartment time.

Follow-up medical exams will be granted to employees as required by thestandard,and/or as deemed necessary by the _______________ medical clinicphysician.

All employees will be granted the opportunity to speak with the physician about theirmedical evaluation, if they so request.

The Program Administrator has provided the ____________ medical clinicphysician with a copy of this program, a copy of the Respiratory Protectionstandard, the list of hazardoussubstances by work area, and for eachemployee requiring evaluation:

his or her work area or job title, proposed respirator type and weight, length of timerequired to wear respirator, expected physical work load (light, moderate, or heavy),potential temperature and humidity extremes, and any additional protective clothingrequired.

After an employee has received clearance and begun to wear his or her respirator,additional medical evaluations will be provided under the following circumstances: Employee reports signs and/or symptoms related to their ability to use a respirator,

such as shortness of breath, dizziness, chest pains, or wheezing. The ______________ medical clinic physician or supervisor informs the Program

Administrator that the employee needs to be reevaluated; Information from this program, including observations made during fit testing

and program evaluation, indicates a need for reevaluation; A change occurs in workplace conditions that may result in an increased

physiological burden on the employee.

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A list of __________________________ employees currently included in medical surveillance isprovided in Table 2 of this program.

All examinations and questionnaires are to remain confidential between the employee and thephysician.

Fit TestingFit testing is required for employees wearing SCBA annually. Employees who are required towear SCBA will be fit tested prior to being allowed to wear any respirator with a tight fittingfacepiece. When there are changes in the employees physical condition that could affectrespiratory fit (e.g., obvious change in body weight, facial scarring, etc.).

Employees will be fit tested with the make, model, and size of respirator that they will actuallywear. Employees will be provided with several models and sizes of respirators so that they mayfind an optimal fit.

The Program Administrator will conduct or provide for fit tests following the OSHA approvedprotocol in the Appendix of the Respiratory Protection standard 1910.134.

The Program Administrator will determined whether QNFT or QLFT is required for therespirators used under current conditions at __________________________ department. Ifconditions affecting respirator use change, the Program Administrator will evaluate on a case-by-case basis which method will be required.

Respirator UseRespiratory protection is required for the following personnel: See Table 2 at end of this program.

TABLE 2: (Example)XYZ Department Personnel in Respiratory Protection Program

Name Department Job DescriptionWork Procedure/Respirator

John Doe XYZ Fire Department - Firefighter Interior Firefighting and IDLH atmospheres.Full facepiece positive pressure SCBA respirator.

General Use Procedures: Employees will use their respirators under conditions specified by this program, and in

accordance with the training they receive on the use of each particular model. Inaddition, the respirator shall not be used in a manner for which it is not certified byNIOSH or by its manufacturer.

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All employees shall conduct user seal checks each time that they wear their respirator.Employees shall use either the positive or negative pressure check (depending onwhich test works best for them) specified in Appendix B-1 of the RespiratoryProtection Standard 1910.134.

All employees shall be permitted to leave the work area to go to the rehab area tomaintain their respirator for the following reasons: to clean their respirator if therespirator is impeding their ability to work, change filters, cartridges, tanks, replaceparts, or to inspect respirator if it stops functioning as intended. Employees shouldnotify their supervisor before leaving the area.

Employees are not permitted to wear tight-fitting respirators if they have anycondition, such as facial scars, facial hair, or missing dentures, that prevents them fromachieving a good seal. Employees are not permitted to wear headphones, jewelry, orother articles that may interfere with the facepiece-to-face seal.

Emergency Procedures:

The following work areas have been identified as having foreseeable emergencies: Structure Fires Transportation Incidents Confined Space Incidents Hazardous Materials Incidents

When emergencies occur, employees that are affected must immediately exit the workarea. __________________________s Emergency Action Plan describes these procedures(including proper evacuation routes and rally points) in greater detail.

Respirator Malfunction

1. SCBA Respirator Malfunction:For any malfunction of an SCBA (e.g., such as breakthrough, facepiece leakage, orimproperly working valve), the respirator wearer should inform his or her supervisor thatthe respirator no longer functions as intended, and go with their buddy to the designated safe areato maintain the respirator. The supervisor must ensure that the employee receives theneeded parts to repair the respirator, or is provided with a new respirator.

All workers wearing SCBA respirators will work with a buddy. Buddies shall assist workers whoexperience an SCBA malfunction as follows:

If a worker in the IDLH environment experiences a malfunction of an SCBA, he orshe should signal to the buddy that he or she has had a respirator malfunction. Thebuddy shall aid the worker in immediately exiting the area.

IDLH ProceduresThe Program Administrator has identified the following area as presenting the potential for IDLHconditions:

Confined Space Incidents:

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Employees will be periodically required to enter a confined space to perform rescue operations. Insuch cases, workers will follow the permit required confined space entry procedures specified inthe __________________________ Departments Confined Space Program. As specified in theseprocedures, the Program Administrator has determined that workers entering this area shall weara SCBA. In addition, an appropriately trained and equipped standby person shall remain outsidethe confined space and maintain constant voice and visual communication with the worker. In theevent of an emergency requiring the standby person to enter the IDLH environment, the standbyperson shall immediately notify the Supervisor/Company Officer and will proceed with rescueoperations in accordance with rescue procedures outlined inthe____________________________ Department Confined Space Program.

Air Quality (Supplied by Vendor)For Self Contained Breathing Apparatus (SCBA) respirators, only Grade D breathing air shall beused in the cylinders. The Program Administrator will coordinate deliveries of compressed airwith the companys vendor, _________________________________ , (name) and require_________________________________ , (name) to certify that the air in the cylinders meets thespecifications of Grade D breathing air.

The Program Administrator will maintain a minimum air supply of one fully chargedreplacement cylinder for each SCBA unit. In addition, cylinders may be recharged as necessaryfrom the breathing air cascade system located near the cascade storage area. The air for thissystem is provided by __________________________s supplier, and deliveries of new air arecoordinated by the Program Administrator.

Air Quality (Supplied by Department Compressor)For Self Contained Breathing Apparatus (SCBA) respirators, only Grade D breathing air shall beused in the cylinders. The Program Administrator will coordinate the operation of the departmentscompressor. The Program Administrator will certify that the air being used from the compressor

meets the state and federal regulations and specifications of Grade D breathing air. The ProgramAdministrator will assure the quality of air and may contract with an approved testing company tocertify the air quality of the departments compressor.

The Program Administrator will oversee the maintenance of the compressor, any replacementparts for the compressor unit.

Cleaning, Maintenance, Change Schedules and Storage

CleaningRespirators are to be cleaned after each use. The cleaning and disinfecting of SCBA will be doneat the designated respirator cleaning station located in the ________________ room.

Respirators or respirator facepiece issued for the exclusive use of an employee shall be cleanedafter each use.

The following procedure is to be used by department certified SCBA maintenance personnel when

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cleaning and disinfecting respirators and only to the level of the training received: Disassemble respirator as recommended by the manufacturer. Wash the facepiece and associated parts in a mild detergent with warm water. Do not

use organic solvents. Rinse completely in clean warm water. Wipe the respirator with disinfectant wipes (70% Isopropyl Alcohol) to kill germs. Air dry in a clean area. Reassemble the respirator. Place facepiece in a clean, dry plastic bag or other air tight container. Any repairs or replacement of defective parts that may be needed will be performed by

manufacturer certified repair centers.

Note: The Program Administrator will ensure an adequate supply of appropriate cleaning anddisinfection material at the cleaning station. If supplies are low, employees should contact theirsupervisor/company officer, who will inform the Program Administrator.

Maintenance

Respirators are to be properly maintained at all times in order to ensure that they functionproperly and adequately protect the employee. Maintenance involves a thorough visualinspection for cleanliness and defects. Worn or deteriorated parts will be replaced prior to use.

No components will be replaced or repairs made beyond those recommended by themanufacturer. Repairs to regulators or alarms will be conducted by the manufacturer ormanufacturer trained personnel.

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The following checklist will be used when inspecting respirators: Facepiece:

Headstraps:

Valves:

Filters/Cartridges/Tank:

Air Supply Systems:

cracks, tears, or holes facemask distortion cracked or looselenses/faceshield

breaks or tears broken buckles

residue or dirt cracks or tears in valve material

approval designation gaskets cracks or dents in housingproper cartridge for hazard. Proper tank pressure, o-ring check andhydro test date.

breathing air quality/grade condition of supply hoseshose connections settings on regulators and valves

Employees are permitted to leave their work area to perform limited maintenance on theirrespirator in a designated area that is free of respiratory hazards.

Change SCBA CylindersEmployees wearing SCBA for protection will exit the IDLH environment and change the cylinderon their respirators when they audio alarm device activates or they experience difficulty breathing(i.e., resistance) while wearing their SCBA.

StorageRespirators must be stored in a clean, dry area, and in accordance with the manufacturersrecommendations. Each employee will clean and inspect their own respirator facepiece inaccordance with the provisions of this program and will store their respirator facepiece in a plasticbag in their own locker. Each employee will have his/her name on the bag and that bag will only

be used to store that employees respirator.

Defective RespiratorsRespirators that are defective or have defective parts shall be taken out of service immediately.

If, during an inspection, an employee discovers a defect in a respirator, he/she is to bring thedefect to the attention of his or her supervisor/company officer. Supervisors/Company Officer willgive all defective respirators to the Program Administrator.

The Program Administrator will decide whether to: Temporarily take the respirator out of service until it can be repaired. Perform a simple fix on the spot such as replacing a headstrap. Remove the respirator from service due to an irreparable problem or defect.

When a respirator is taken out of service for an extended period of time, the respirator will betagged out of service, and the employee will be given a replacement of similar make, model, andsize. All tagged out respirators will be kept in the storage cabinet inside the ProgramAdministrators office or designated area.


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TrainingThe Program Administrator will provide training to respirator users and theirSupervisors/Company Officer on the contents of the ________________________ DepartmentsRespiratory Protection Program and their responsibilities under it, and on the OSHA RespiratoryProtection standard. Workers will be trained prior to using a respirator in the workplace.Supervisors/Company Officer will also be trained prior to using a respirator in the workplace orprior to supervising employees that must wear respirators.

The training course will cover the following topics: the __________________________ Department Respiratory Protection Program the OSHA 1910.134 Respiratory Protection standard respiratory hazards encountered at fires, hazardous materials incidents and other

situations that require the use of SCBA and their health effects proper selection and use of respirators limitations of respirators respirator donning and user seal (fit) checks

fit testing emergency use procedures maintenance and storage medical signs and symptoms limiting the effective use of respirators

Employees will be retrained annually or as needed (e.g., if they are issued new or differentrespirator). Employees must demonstrate their understanding of the topics covered in the trainingthrough hands-on exercises and a written test. Respirator training will be documented by theProgram Administrator and the documentation will include the type, model, and size of respiratorfor which each employee has been trained and fit tested.

5.0 Program EvaluationThe Program Administrator will conduct periodic evaluations of the workplace to ensure that theprovisions of this program are being implemented. The evaluations will include regularconsultations with employees who use respirators and their Supervisors/Company Officer,inspections and a review of records.

Problems identified will be noted in an inspection log and addressed by the ProgramAdministrator. These findings will be reported to __________________________ departmentmanagement, and the report will list plans to correct deficiencies in the respirator program andtarget dates for the implementation of those corrections.

6.0 Documentation and RecordkeepingA written copy of this program and the OSHA standard is kept in the Program Administratorsoffice and is available to all employees who wish to review it. Also maintained in the ProgramAdministrators office are copies of training and fit test records.

These records will be updated as new employees are trained, as existing employees receiverefresher training, and as new fit tests are conducted.


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The Program Administrator will also maintain copies of the medical records for all employeescovered under the respirator program. The completed medical questionnaire and the physiciansdocumented findings are confidential and will remain at ______________________ Clinic. The______________________ Department will only retain the physicians written recommendationregarding each employees ability to wear a respirator.


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TABLE 2:__________________________ Department Personnel in Respiratory Protection Program

Name Department Job Description

Work Procedure/Respirator

______________________ Fire Department - FirefighterInterior Firefighting and IDLH atmospheres.Full facepiece positive pressure SCBA respirator.












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______________________ Fire Department - Firefighter

Interior Firefighting and IDLH atmospheres.Full facepiece positive pressure SCBA respirator.






______________________ Fire Department - FirefighterInterior Firefighting and IDLH atmospheres.

Full facepiece positive pressure SCBA respirator.








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TABLE 3: ________________________ Department Hazard Assessment - January 1999

Operation Contaminants Exposure Level PEL Controls

Fire SuppressionInteriorStructure

By products ofincompletecombustion

Various Various Mandatory useof SCBA

Fire Suppression By products of Various Various Mandatory use


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Vehicles andTransportation

incompletecombustion

of SCBA

Fire SuppressionGrass andVegetation

By products ofincompletecombustion

Various Various Mandatory useof SCBA whenrequired

HazardousMaterialsIncidents

By products ofincompletecombustion,vapors andliquids

Various Various Mandatory useof SCBA andprotectiveequipment

Confined SpaceIncidents

By products ofincompletecombustion,vapors andliquids


TrainingEvolutions

By products ofsimulationsmoke


DepartmentMaintenanceActivities

By products ofvapors andliquids

Various Various Mandatory useof SCBA andprotectiveequipment


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APPENDIXREFERENCES

Minnesota Department of Labor and Industry (MN-OSHA)Department of Labor & Industry, 443 Lafayette Road, St. Paul, MN 55155Phone 651-296-6107 * 1-800-DIAL-DLI * (TTY) 651-297-4198

MN-OSHA; Web site: http://www.doli.state.mn.us/

Questions and Answers on the Respiratory Protection StandardOSHA PublicationAvailable from OSHA web site: www.OSHA.gov

OSHA Instruction: Inspection Procedures for the Respiratory Protection StandardOSHA PublicationAvailable from OSHA web site: www.OSHA.gov

Respirator Selection GuideOSHA Publication

Available from OSHA web site: www.OSHA.gov

Small Entity Compliance Guide for the Revised Respiratory Protection Standard.OSHA PublicationAvailable from OSHA web site: www.OSHA.gov

Documentation of the Threshold Limit ValuesACGIH Publications Office, 6500 Glenway Ave., Building D-5, Cincinnati, OH 45221

NIOSH/OSHA Pocket Guide to Chemical HazardsNational Institute for Occupational Safety and HealthPhone Number: (800-356-4674); Web site: www.cdc.gov/niosh/homepage.htmlANSI Respirator Standard 1992 Z88.2

Condensed Chemical DictionaryGessner G. Hawley, Van Nostrand Reinhold Co., 135 W. 50th St., New York, NY 10020

Industrial Respiratory ProtectionNIOSH PublicationNational Institute for Occupational Safety and HealthPhone Number: (800-356-4674); Web site: www.cdc.gov/niosh/homepage.html

Respirator Decision LogicNIOSH PublicationNational Institute for Occupational Safety and Health

Phone Number: (800-356-4674); Web site: www.cdc.gov/niosh/homepage.html

NIOSH Guide to the Selection and Use of Particulate Respirators Certified Under 42 CFR 84National Institute for Occupational Safety and HealthPhone Number: (800-356-4674); Web site: www.cdc.gov/niosh/homepage.html


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Subject:Resp Program -Reply

Date:Tue, 19 Jan 1999 10:49:32 -0600

From:Patricia Lorentz

To:[email protected]

Warren,

I have reviewed the sample respiratory protection program you sent and don't see any glaringomissions. All of the elements of the standard appear to be covered and there seems to beadequate information to point people in the right direction in setting up each element of the

program. As with all written programs, we would stress the importance of implementation - - thewritten program is useless unless it's implemented. OSHA looks at not only the written programbut at how that program is implemented in the workplace.

I would suggest one additional reference for Appendix --Federal OSHA has published a "SmallEntity Compliance Guide for the Respiratory Protection Standard" that can be accessed throughthe "publications" area of the federal website (www.osha.gov). This guide puts the standard inplain language (for the most part) and provides checklists for many of the elements (i.e., medicalevaluations, fit testing, etc.). Table 2 on page f-9 has come in handy when people have asked fora clear "black on white" statement as to whether or not both QLFT and QNFT are acceptable forfit-testing SCBA. The chart answers that very clearly.

In conclusion, I think you have a good product here that will be very useful to fire departments indrafting their respirator programs.

If I can provide any additional information, please don't hesitate to contact me.

Pat L.MNOSHA

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